b
632.954
USGanwd
1986 ^11 ^
Canada Thistle
Spotted Knapweed
//V'' Leafy Spurge
USDA Forest Service
Gallatin
National Forest
‘NPXIOUS
‘W&ED
CONTROL
MONTANA STATS liS«ARf
ISIS E. Sth AVS.
IIEIENA, MONTANA MMa
Environmental
Impact Statement
"Draft
STATE DOCWMENTS COLLECTION
MAY 2 2002
MONTANA STATE LIBRARY
.. 1515 E. 6th AVE.
HELENA, MONTANA 59620
June 1986
MftR 27^9*1
MONTANA STATE LIBRARY
S S32.9S4 USGAnwd 1986 c.2
Gallatin National Forest noxious weed co
3 0864 00060125 5
DBAFT ENVIRONMENTAL IMPACT STATEMENT
Gallatin National Forest
Madison, Meagher, Gallatin, Park, and Sweetgrass Counties, Montana
U.S.D.A. - Forest Service
No other Agencies (State or Federal)
Robert E. Breazeale
Forest Supervisor
Gallatin National Forest
P.O. Box 130
Bozeman, MT 59771
Richard H. Inman
Staff Officer
Gallatin National Forest
P.O. Box 130
Bozeman, MT 59771
(406) 587-6705
Abstract: This Draft Environmental Impact Statement documents the analysis of
four alternatives, including "no action," which were developed for the
management and treatment of noxious weeds on the Gallatin National Forest. The
Gallatin National Forest covers 1,735,412 acres, of which, approximately 2,800
acres are infested with dense stands of noxious weeds and about 143,000 acres
are lightly infested.
The alternatives considered provide different approaches to weed management
resulting in different levels of control. These alternatives are: (1) No
Action; (2) Cultural and Biological control; (3) Chemical and Biological
control; (4) Integrated Pest Management. Alternative (4) is the Forest Service
preferred alternative. This alternative provides for treating noxious weeds in
an integrated pest management approach using a combination of chemical,
cultural, and biological means. Chemical control would be emphasized, using
herbicides applied on the ground to target weeds by truck mounted or hand-held
nozzles or solid pellets.
Please retain your copy of this Draft Environmental Impact Statement (EIS). If
changes to the Draft EIS in response to comments are minor and are confined to
factual corrections or explanations wliy the comments do not warrant further
agency reponse than only the comments, the responses and the changes will be
circulated and not the Final EIS. (40 CFR 1503.4(c)).
Lead Agency:
Cooperating Agencies:
Responsible Official:
For Further
Information Contact:
f
The Absaroka-Beartooth Wilderness and the Lee Metcalf Wilderness will not
receive any treatment with herbicide until the Begional Forester has approved a
course of action specifically for them. Hand grubbing would be permitted at
this time
Comments regarding this statement should be sent to the Forest Supervisor,
Gallatin National Forest, P.O. Box 130, Federal Building, Bozeman, Montana,
59771. Comments must be received by August 15, 1986.
-2-
«
SUMMAKT
This Draft Environmental Impact Statement (EIS) describes and analyzes the
environmental impacts of implementing a program of controlling noxious weeds on
public land administered by the United States Forest Service. These lands are
administered by the Gallatin National Forest in the Gallatin, Madison, Meagher,
Park, and Sweetgrass counties within the State of Montana. Noxious weeds are
rapidly spreading throughout the State of Montana, causing a variety of
ecological, social and economic impacts to agricultural lands, forest and
rangeland, wildlife lands, watersheds, and other resources. About 146,000
acres of lands containing noxious weeds have been identified on the Gallatin
National Forest. These lands range from 107,000 acres containing occasional
noxious plants to 2,800 acres of dense stands of noxious weeds.
Several laws provide the authority for this proposal and date from the Granger-
Thye Act of 1925 to the Rangeland Improvement Act of 1978. The term "noxious
weeds" is a legal designation and not a biological term. State laws provide
for designation of certain plant species as "noxious" and require landowners to
control them. Recent legislation enacted within the state of Montana make it
mandatory for landowners to provide management plans and alternatives for the
control and eradication of these noxious weeds.
The Gallatin National Forest has organized an interdisciplinary team to analyze
the noxious weed problem in accord with Forest Service policies and the
National Environmental Policy Act. The scoping phase of the environmental
analysis process revealed specific issues involved in noxious weed
management.
-3-
I
t
The issues of greatest public concern were: (1) the human health risk
associated with chemical treatmentj (2) the losses to vegetative productivity
associated with noxious weed infestations, (3) the rate of spread of noxious
weeds, (4) the need to cooperate with other agencies and landowners in weed
control, (5) effects oji threatened and endangered animals and plants, (6) the
need to inform forest visitors and Forest Service personnel of the noxious weed
problem, (7) the legal obligation of the Forest Service to maintain, enhance
and preserve the natural resource within its changes.
Alternatives Considered
To fully consider the issues and concerns that were identified during the
scoping process a range of alternatives were developed by the interdisciplinary
team, including: (1) no action, (2) cultural and biological control, (3)
chemical and cultural control, and (4) integrated pest management. A brief
description of each alternative follows.
Alternative 1 - - No Action
Under this alternative no attempt will be made to control or contain the spread
of noxious weeds from coming onto or leaving National Forest System lands. Any
control would only be a natural function of the environment with no planned
intervention by land manager.
-4-
Alternative 2 - - Cultural and Biological Control
Mechanical methods (tillage, mowing, and hand grubbing) would be the primary
tools used to control noxious weeds under this alternative. In addition to
mechanical methods, prompt revegetation of soil disturbed by road construction,
building sites and timber harvest activities would be implemented. Biological
control involves using natural insect and disease enemies (parasites, predators
or pathogens) that will attack individual noxious plant species to retard
growth or prevent seed formation. At the present, the Leafy Spurge Hawk Mouth,
the Canada Thistle Stem Mining Weevil and two Knapweed Seed-Head Gall Flies
have been introduced into the environment. This alternative would provide for
continued monitoring of these bio-agents and new releases as available.
A1 ternati ve 3. .- - Chemical and Biological Control
Noxious weed control would be accomplished primarily by the ground application
of the herbicides picloram and 2,4-D. Ground application of herbicides would
be accomplished mostly by spot application from hand-held nozzles, either from
vehicle mounted sprayers or backpack tanks. Biological control under
alternative (3) would be the same as under alternative (2) above.
-5-
f
.4. r. Integrated Pest Management (Preferred Alternative)
Alternative (4) would involve an integi atf d pest inanagemen t approach to noxious
weed conlTol .In coovd mi..' 'ci' \ ■ . ’ ” T..
lands. Alternative (4) provides for the applicatior c f ;'i l t g. . ' ^ -
management principles, but emphasizes chemical control as the primary method.
Biological control efforts including ncini tor i rg current control efforts and
introducing new i agen's, x ' ’ 1 (((:(’’), 'id ’’i T, : gi. ’ . d
Insect Laboratory of the U.S.D.A. Agriculture Research Service (Icc.'d
Bozeman, Montana). Control of Leafy Spurge with sheep grazing at several sites
will also be attempted.
Cultural weed control by manual hand grubbing would be applied to weeds in
wilderness areas, within rare plant habitat and other selected sites. Chemical
control under alternative (4) would be applied on approximately 275 acres in
1987-1990. As in alternative (3) the herbicides 2,4-D and picloram would be
spot applied to individual weeds by hand-held nozzle or pellet form. An active
public information program would be a implemented under this alternative also.
AFFECTED ENVIRONMENT
The principal noxious weeds on the Gallatin National Forest are Leafy Spurge,
Spotted Knapweed, Canada Thistle, Musk Thistle, Whitetop, Dalmation Toadflax,
Hounds Tongue, and Yellow Toadflax. Areas affected by noxious weeds include
forest land, rangeland, rights-of-ways, riparian zones and occupancy sites.
Approximately 146,000 acres of forest land contain noxious weed infestations.
This acreage includes 107,900 acres containing occasional plants, 37,900 acres
of widely scattered infestation and 2,800 acres of dense infestation.
-6-
%
The forest has three threatened and endangered animal species: grizzly bear,
bald eagle, and the peregrine falcon. All three species habitiat occurs on all
five Ranger Districts on the forest. A biological evaluation has been
conducted to analyze the effects of noxious weed control on these threatened
and endangered species.
The Gallatin National Forest consists of 1,735,412 acres of National Forest
system lands, with 415,826 acres of other ownership with the forest boundary.
The Forest consists of six mountain ranges and one high-altitude plateau.
Slopes on the Forest are characteristically steep. Climatic zones vary with
altitude from the semiarid and relatively warm valley bottoms through a broad
range of cool, moist coniferous forests to the subalpine and alpine regions
characterized by high altitude rocklands.
About 1.3 million acres of the Gallatin's total 1.7 million acres are forested.
Primary commercial tree species on the Forest are lodgepole pine, Douglas-fir,
alpine fir, and spruce. Whitebark pine stands occur on the Forest near the
timberline. Bunchgrass, forbs, and related species of flora comprise the more
valuable forage on the Forest's rangelands. Elk, deer, and commercial
livestock all use these rangelands in different places or at different times.
Riparian vegetation along streams or wetlands is of high value on the Gallatin
to provide habitat, forage, and browse for wildlife and domestic livestock; to
reduce sedimentation in streams; and to retard runoff that might otherwise
contribute to flooding.
The Gallatin National Forest exerts a significant economic influence on
Gallatin, Park, and Sweetgrass counties. Towns that are affected by activities
on the Forest include Bozeman, Livingston, West Yellowstone, Gardiner, and Big
Timber. The area-of-inf luence of the Forest had a population of 63,000 persons
in 1980.
In 1980, 2,022,000 recreation visitor days were recorded on the Forest.
Thirty-four percent of this use was at developed recreation sites and 66
percent was dispersed use, such as hiking, camping, and backpacking. Dispersed
use occurs in wilderness and nonwilderness areas. Future recreation use is
expected to increase.
The Gallatin National Forest contains the greater part of two wilderness areas,
the Absaroka-Beartooth and Lee Metcalf wilderness. The Forest also contains
the congressionally designated Cabin Creek Recreation and Wildlife Area.
In addition, 12 roadless areas totaling 637,600 acres had been inventoried on
the Forest as of September 1984.
The Gallatin Forest provides habitat for approximately 330 wildlife species.
Elk herds, both resident and migratory, and a large native population of mule
deer are the most abundant big game species. The Forest also has stable
populations of moose, bighorn sheep, mountain goats, black bear, and
white-tailed deer.
Fish found on the Gallatin include cutthroat, rainbow, brown, golden, and brook
trout, rainbow-cutthroat, hybrids, arctic graylings, and mountain whitefish.
The Forest contains 1,052 miles of fishing streams. Three major rivers that
cross the Forest — the Gallatin, Madison, and Yellowstone, merit national
attention as "blue ribbon" trout streams.
-7-
At present, about 164 permittees are grazing livestock on 148 active grazing
allotments on the Gallatin National Forest. These allotments constitute
approximately 165,800 acres of rangeland. The current domestic livestock
grazing level on the Forest Service is 38,920 Animal Unit Months per year from
permanent range.
At present, about 428,000 acres of the Gallatin National Forest are classified
as available and capable for timber management activities. The Forest now has
314,000 acres in the timber base. About 33,600 acres of productive Forest land
are presently unavailable for timber and other wood products because they are
being studied for wildermess suitability under the Montana Wilderness Study
Act. The annual harvest from the Gallatin within the past 10-year period has
ranged from 7 to 25 million board feet, averaging 13.2 MMBF cut per year. The
annual sell in recent years has Increased due to efforts to salvage lodgepole
pine killed or threatened by a mountain pine beetle epidemic.
The Gallatin National Forest produces about 2,028,000 acre-feet of water
annually. This water yield is greatest during the period of spring runoff.
The ability of watersheds to moderate this runoff is important for controlling
erosion, assuring water quality, and reducing the hazard of flooding. Riparian
vegetation on the Gallatin is important in stabilizing streambanks and
achieving these benefits.
Major storage reservoirs on the Forest include Hyalite and Hebgen lakes. There
are three municipal watersheds on the Gallatin Forest. Bozeman is the largest
municipality served from waters originating on the Forest.
The Forest also has 91 special use permits for water-related facilities, such
as water lines, stock watering facilities, reservoirs, and irrigation ditches.
Streamflow arising on the Forest is used to irrigate 439,000 acres of cropland
and hayland in five counties.
The Forest currently has 807 miles of Forest development roads on its
inventoried system. Approximately 250 miles are maintained annually by the
Forest Service. The Forest makes available 1,853 miles of trails for riders
and hikers. About 28 percent of the trail system is presently in need of
repair or relocation. Developed recreation facilities on the Forest include
campgrounds (37), picnic areas (14), developed downhill ski areas (2), boat
launches (5), and a visitor information center at Earthquake Lake. The Forest
also has a number of existing powerline corridors crossing Forest Service land.
These corridors include powerlines through Flathead Pass, a powerline up the
Gallatin Canyon, and several powerlines in the Hebgen area serving the town of
West Yellowstone.
ECONOMIC IMPLICATIONS OF NOKIODS WEEDS
Spotted Knapweed ranks as the number one weed problem on rangeland in Montana.
It reduces livestock and big game forage, damages wildlife habitat, and can
double the amount of soil erosion from sites where it invades rangeland.
Knapweed is estimated to cause an annual loss of forage valued at 4.5 million
dollars in Montana. Leafy spurge is considered as the most persistent of the
identified noxious weeds. Its inhabitance creates the loss of hay and beef
cattle production, wildlife habitat, and other resource values.
-8-
\
ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES
AJ-Jtjejjifi.tiye. J. No Action
Left unchecked the noxious weeds would continue to spread on the Forest, and
the cost of weed control would more than double in 5 years. Forage production
would decline on the weed infested range areas, reducing forage available for
livestock and wildlife.
There are toxins produced in leafy spurge and spotted knapweed which limit the
growth of competing plants and often result in the development and perpetuation
of a weed monoculture. The most drastic biological effect that this could have
would be the elimination of the rare plant species. As knapweed and leafy
spurge increase and crowd out more favorable forage plants, the habitat for
many wildlife species would likely deteriorate. Impacts to fisheries would be
in the form of potential increases of sedimentation and decreases of bank
stability assciated with the noxious weeds crowding out more desirable
vegetation.
There would be no human health risk associated with the No Action alternative.
Alternative 2 - - Cultural and Biological Control
In the long-term, the most cost-effective control of noxious weed species will
likely come from introduction of biological agents that limit the
aggressiveness and range of these weeds. However, development of biological
control is a very slow process. The biological control insects currently
available are not expected to adequately reduce knapweed, leafy spurge or other
noxious weed problems on the Gallatin National Forest in the near future.
Until additional bio-agents are introduced that are effective in controlling
the noxious weeds on the Forest, biological control will likely have only
minimal impacts on noxious weed infestations.
Intensive cultivation necessary to control noxious weeds is not practical on
the steep, rocky range and forest land of the National Forest. Only hand
grubbing and some roadside mowing could be used. These treatments would have
to be repeated annually for an indefinite period to control the weeds. The
cost of cultural methods as the sole treatment is several times the cost of any
of the other alternatives. In addition, mechanical treatment is not effective
against rhizomatous plant which can spread vegetatively (regenerating from
rhizomes) . Mechanical treatment of leafy spurge can increase its rate of
spread under some conditions. Soil disturbance and erosion would increase more
under mechanical weed control than under other alternatives. Mechanical
treatment by grubbing could potentially disturb unindentif ied archeological
resources .
The human health risk associated with the mechanical treatment alternative
would be the safety hazard for workers using small hand tools in grubbing out
weeds, and for operating mowing and tillage equipment. There would be little
or no hazard to the general population.
-9-
Mechanical treatment of some weeds such as knapweed would improve the forage
resources for livestock in the long run. However, there would be a high risk
of the reinvasion of noxious weeds on the disturbed soil. Reseeding with
favored plant species can reduce this risk. Overall the forage improvement
under this alternative would be intermediate to Alternatives (1) and (4).
Alternative 3 Chemical and Biological Control
Research shows that the application of herbicide can provide effective control
of the target weeds. The herbicide picloram may remain in the soil, killing
weeds for two or more years after application.
Following herbicide treatment on the project area, forage production would be
rapidly improved on target acres of rangeland. The proposed chemical treatment
is expected to cause only a short-term decline of diversity in wildlife habitat
cover, by favoring the growth of grasses over broadleaf forbs and shrubs on the
area treated. There are no known Federally listed threatened and endangered
plants on the Gallatin National Forest. Unidentified populations of threatened
and endangered plants could be susceptible to any impacts described for
terrestrial vegetation. Direct effects of injury or death to plants could
immediately eliminate a species in a portion of its range. Increased
competition from aggressive noxious weed species could also eliminate a
species.
The herbicides that are proposed for use in chemical control (2,4-D and
picloram) both have a low level of toxicity. The procedure of spot application
makes the risk of any adverse effects on wildlife species very low. Herbicide
concentration on vegetation would be below levels that affect grazing and
browsing animals. Threatened grizzly bear occupied habitat would be involved
in treatment with herbicides. However, because the treatment is largely
roadside rights-of-way, the area affected is of low habitat effectiveness for
the grizzly bear. Therefore, no adverse effects would be expected on the
grizzly bear or other threatened or endangered species. Small quantities of
herbicides could enter streams through drift, but limiting spraying to wind
conditions of 10 mph or less will minimize this drift.
Some herbicides could also enter streams in surface runoff or through erosion
of previously treated soils. Where streamflow results from thunderstorms,
surface runoff may flush herbicide residuals into streams in detectable levels,
under resonable foreseeable conditions the herbicide concentration would be
below levels that affect fish survival. The human health hazard for
Alternative (3) is similar to Alternative (4), and is discussed in the next
section.
Alternative 4 - - Integrated Pest Management (Preferred Alternative)
The environmental consequences of the integrated pest management alternative
include a combination of the effects discussed above in Alternatives (1-3),
differing in the extent to which each method is applied. Mechanical treatment
by hand grubbing of selected areas would minimize the risk of exposing rare
plant habitat to herbicide, and reduce herbicide treatment in campgrounds to
only dense weeds that are impractical to mechanically hand grub.
-10-
The impacts of herbicide treatment on wildlife, fishery habitat and threatened
and endangered species would be similar to the consequences described in
Alternative (3).
To evaluate the human health hazard associated with the application of
herbicides the Forest Service reviewed the hazards of commonly applied
herbicides including picloram and 2,4-D at the National, Regional and Forest
levels. An analysis specific to Alternative (4), assessed potential impacts of
the herbicide treatment proposed on the Galllatin National Forest. A summary
of some of the more important points of the site-specific analysis follows.
Members of the general public are unlikely to be exposed to herbicide from most
projects proposed on the Gallatin National Forest. Most herbicide application
occurs on remote sites and at distances of over a mile from the nearest
residence.
Visitation of these sites would be extremely rare. An exception would occur
with the proposed application of a small amount of herbicide on 5 trailheads, 3
campgrounds and the visitor center at Earthquake Lake. In all cases, these
areas would be closed during spraying and the spray area closed for 2 days
after spraying.
With few exceptions, possible doses to the general public are below the
acceptable daily intake (ADI) for 2,4-D and picloram. The ADI is defined as
the dose of a pesticide that could be taken daily for a lifetime without
adverse health impacts. Worker doses are likely to be much higher than general
population doses. Although worker health can be adequately protected during
picloram application by requiring use of protective clothing, 2,4-D exposure
could exceed the ADI for projects requiring large daily applications. The
possibility of minor effects on kidney function can not be conclusively ruled
out based on the data currently available. However, because of the relatively
"short" term, intermittent exposive of workers (three work weeks or less per
year) long term effects on kidney functions are not expected. The importance
of careful application techniques and use of protective clothing must be
emphasized to workers.
The calculated risks of cancer from exposure to the pesticides applied in the
proposed projects are below those associated with natural background exposure
to carcinogens that humans encounter on a daily basis. This level of cancer
risk is accepted by the Food and Drug Administration and the Environmental
Protection Agency. The possible cummulative and synergistic impacts of Forest
Service spraying, in addition to impacts from other spraying are not reasonably
expec ted .
-11-
TABLE OF CONTENTS
A. PURPOSE AND NEED FOR ACTION
1. Introduction
2. Background
3. Control Efforts to Date
4. The Issues
B. ALTERNATIVES CONSIDERED
1 . No Action
2. Cultural and Biological Control
3. Chemical and Biological Control
4. Intergrated Pest Management
C. AFFECTED ENVIRONMENT
D. ENVIRONMENT CONSEQUENCES OF ALTERNATIVES
E. MANAGEMENT CONSTRAINTS
F. LIST OF AGENCIES AND PERSONS TO WHOM COPIES ARE SENT
G. LIST OF PREPARERS
H. APPENDIX
1. Reference
a. Bibliography
b. Glossary
2. Resource Specialists' Reports
a. Biological Evaluation for Noxious Weed Plan
b. Fisheries Biologist's Report
3. Proposed Mechanical Treatment by Districts Alternative #2
4. Proposed Ground Application of Herbicides by District Alternative #3
5. Proposed Integrated Treatment by District Alternative #4
6. Est. Cost of Noxious Weed Control by Method of Treatment & District
7. Detailed Listing of Projects by District
a. Big Timber Ranger District (D-1)
b. Livingston Ranger District (D-2)
c. Gardiner Ranger District (D-3)
d. Bozeman Ranger District (D-6)
e. Hebgen Ranger District (D-7)
8. Human Health Risk Analysis
a. Gallatin National Forest
b. Northern Region
9. Pesticide Labels
a. Tordan 22K (Picloram)
b. Tordan 2K pellets (Picloram)
c. 2,4-D Amine
10. File letter with attachments, Montana Natural Heritage Program
-12-
A. PURPOSE AND NEED FOR ACTION
1 • Introduction
Noxious weeds are rapidly spreading throughout the State of Montana on
both private and publicly owned lands. Noxious weeds are having major
impacts on agricultural lands, rangelands, and wildlands. Noxious
weed control programs have been implemented on the Gallatin National
Forest for many years. These control efforts typically have been
closely coordinated with county weed control programs.
The term "noxious weed" is a legal designation and not a biological
term. County and State laws designate certain plant species as
"noxious" and require landowners to control them. A "weed" is a plant
outside its desired location or plant where it is not wanted. All
species considered noxious on the Gallatin National Forest are native
to another location. Most of our noxious species came from Europe and
Asia in the early part of this century, often imported as an impurity
with crop seed and hay, or domestic livestock. Removed from their
natural ecosystems, predators and competitors, these species rapidly
spread in their new environment. The decrease of desirable native and
domestic species that occurs with the increase in these undesirable,
unpalatable (and sometimes poisonous) species is the essence of what
is referred to as noxious weed problem.
Secretary of Agricultural Regulation 36 CFR 222.8 delegates to the
Chief, Forest Service, authority to cooperate with Federal and State
agencies in control of noxious farm weeds and use of pesticides. The
' objectives are to apply the Secretary '^s Regulation 36 CFR 222.8
relating to noxious farm weed as follows; (1) Control noxious farm
weeds on Forest Service administered lands in cooperation with State
and County weed control organizations. (2) Prevent invasion of
National Forest Service range by noxious farm weeds through the
establishment and maintenance of beneficial plant cover on all range
areas. (3) In cooperation with Federal and State agencies, the Forest
Service will monitor pesticide applications to insure effectiveness,
placement accuracy, and minimal non-target effects. In addition to 36
CFR 222.8, Sections land 2 of the Carlson-Foley Act (82 stat. 1146,
P.L. 90-583), October 17, 1968, and section 9 of the Federal Noxious
Weed Control Act of 1974 (P.L. 93-629) gives direction to the Forest
Service for control of noxious farm weeds.
In addition to the above Federal Regultions and Laws, Section 16-1706
of the Montana Weed Law makes it illegal "to permit any noxious weed,
as named in the act, or designated by the board of county
commissioners of the respective county to go to seed on any lands
within the area of any district."
Noxious weeds recognized by the State of Montana are;
Canada Thistle
Wild Morning Glory or Bindweed
White top
Leafy Spurge
Russian Knapweed
Circium arvens.e
Convovulus arvensis
Cardaria drab a
Euphorbia esul a
-13-
Many other weed species have been designated as noxious by County Weed Boards
under the Montana State Weed Law. Target species for this program are:
Canada Thistle
Leafy Spurge
Russian Knapweed
Spotted Knapweed
Oxeye Daisy
Toadflax
Musk Thistle
Hounds tongue
Tansy Ragwort
1 eu.c an.themum
Linaria Vulgaris
Cardus nutans
Tancetum yulgare
2.
Over 2,500 acres of the Gallatin National Forest have "dense stands"
of "noxious weeds" as so classified by Federal, State or County weed
laws. The acreage by species is listed below:
Occasional Plant
Acres
Widely Scattered
Dense Stand
Plant Acres
Canada Thistle
15,000
3,500
750
Cluster Tarweed
300
200
100
Cocklebur
2,500
1 ,000
300
Curlycup Gumweed
7,500
2,500
200
Dalmation Toadflax
700
400
100
Hounds tongue
75,000
25,000
350
Knapweed spp.
600
250
100
Leafy Spurge
1,800
450
200
Musk Thistle
3,000
1 ,500
500
Oxeye Daisy
1 ,000
500
100
Whitetop
500
300
100
Wyethia
- - —
100
-
TOTAL
107,900*
35,700*
2,800*
The above
listed noxious weeds effect the National
Forest land
resources
in several different ways. When forage
production is
reduced both domestic livestock and big game populations are
affected .
Along with forage production loss there
is a loss in
quantity
and/or quality of
habitat for small game.
birds, and
fisheries
. Visual quality
of recreation areas is
lost. Tree surv
rates among saplings is reduced and growth affected.
*(Howarth, 1983)
-14-
3. Control Efforts to Date
Control efforts have been hampered by low funding. The forest has stretched
limited appropriated funds by utilizing the range betterment funding
cooperating with County weed district efforts.
The funds expended and acres of noxious weeds treated 1983-1986 are summarized
below:
Acx£i
$ Spent
1983
35
1,715.00
1984
175
10,282.00
1985
424
18,135.00
1986
344
11,885.00
The Forest is cooperating with County Weed Boards in controlling noxious farm
weeds to ensure a coordinated approach to this widespread problem. In
Galllatin, Park, and Sweetgrass counties, the County Weed Control Crews are
treating weeds on the National Forest in a cooperative effort with the Forest
Service-
Biological weed control agents are being utilized, as they become available, in
an integrated pest management effort. Insects that attack and feed on the seed
of musk thistle and spotted knapweed plus leafy spurge have been released on
the Forest in cooperation with the Rangeland Insect Laboratory (U.S.D.A.-
A. R. S . ) .
The scoping phase of the environmental analysis process revealed two
main issues in the noxious weed problem:
a. Loss of Agricultural Production
The concern over the threat to agricultural production from the
introduction and spread of noxious weeds on the Forest is a major
issue. The local agricultural community and various local State and
Federal agencies have expressed this concern.
b. Public Health and Safety
Public health and safety in the use of pesticides to control noxious
weeds is another issue. Much of this concern has been expressed at
the regional and national level. For example, this concern is
expressed in recent court decisions in Oregon involving the BLM and
the Forest Service (Ecosystems vs. Clark and Merrell vs. Block).
c. Other Issues and Management Concern
The effects of noxious weeds and/or herbicide on native vegetation and
wildlife habitat, particularly threatened grizzly bear and Peregrine
falcon habitat, where other concerns considered during the evaluation.
-15-
B. ALTERNATIVES CONSIDERED
To fully consider the issues and concerns that were identified during the
scoping process a range of alternatives were developed by the
interdisciplinary team. Some alternative components are available with
more than one alternative. Preventative weed control measures would be
implemented under all alternatives. These include aggressive revegetation
of newly districted areas, improved range condition through range
management, and public education.
Because of budget limitations the forest noxious weed strategy has been
directed to the containment of new infestations as opposed to
erradication. Erratication efforts are directed to new and small
infestation. In addition, high priority is given to investigation and
locations from which rapid migration to uninfested areas could occur.
The site specific projects are identified in appendix 7, A through E.
The alternatives include (1) no action, (2) cultural and biological control,
(3) chemical and biological control, (4) integrated pest management. A
description of each alternative follows. The proposed treatment and cost of
the alternatives are compared in Table I following the narrative discussion.
1 . Alternative 1 - - No Action
Under this alternative no attempt will be made to control or contain
the spread of noxious weeds from coming onto or leaving National
Forest System lands. Noxious weed species will be allowed to continue
unchecked in their invasion of native vegetation. There would be no
cooperation with the counties and adjacent private landowners in their
on-going weed control efforts.
2. 2. - r. Cyj.iuxiil_aiid. gicIpgical_ifiiitxQl
Mechanical methods (tillage, mowing and hand grubbing) would be the
primary tools used to control noxious weeds under this alternative.
Properly timed, these methods prevent plants from producing seeds and
repeated efforts can deplete the root food supply of some perennials.
These methods are usually limited by terrain, access and cost. The
specific treatment and costs are shown by project on Table I -
Proposed Mechanical Treatment of Noxious Weeds - Alternative (2).
Other cultural weed control applied under this alternative would
include the prompt revegetation of soil disturbed by road
construction, and the application of improved grazing practices as
allotment management plans are implemented.
Biological control involves using natural insect and disease enemies
that will attack individual noxious plant species to retard growth or
prevent seed formation. At the present time, the only proven
effective biological control agent in Montana is a seed-head weevil
that attactks musk thistle (Rhinocyclus conicus) . Two seed-head gall
flies (Urophora affinis and U. quadrifasc iata) have been released on
spotted knapweed. In British Columbia, where both fly species are
-16-
established, spotted knapweed seed reductions of 95% have been
reported. However, since seed production in dense stands can be from
7,000 to 90,000 per square meter, there would remain 350 to 2,000
seeds per square meter to maintain or spread the knapweed. There are
other bio-agents that are in various stages of development in Montana
including a leafy spurge defoliating moth (Hyles euphorbiae) , a Canada
thistle stem mining weevil ( Eutorhynchus letura), and a spotted
knapweed seed-head moth (Metzneria pauc ipunc tella) (Montana State
University. Dec. 1984).
-17-
Both the musk thistle seed-head weevil and the leafy spurge
defoliating moth have been released on the Forest previously. This
alternative would provide for continued monitoring of these
bio-agents. New release of the leafy spurge defoliating moth would be
made as the agent becomes available.
The area to be treated (275 acres - net) are specified by project in
Appendix 3, Proposed Mechanical Treatment Alternative (2).
3 . AJ. iexDflliyfi- 3. - - Chemical and Biological Control
Noxious weed control would be accomplished primarily by the ground
application of the herbicides picloram, and 2,4-D in Alternative (3).
The area to be treated (275 acres - net) and the quantity of herbicide
to be applied (382.7 pounds of 2,4-d and 167.1825 pounds of Picloram)
are specified by project in Appendix 4, Proposed Ground Application of
Herbicides - Alternative (3).
Ground application of herbicides will be accomplished mostly by spot
application from hand held nozzles, either from vehicle mounted
sprayers or backpack tanks. Weeds remote from road access and/or
water will be treated with solid herbicide in the form of picloram
(Tordon 2K) beads.
The herbicides would be applied in coordination with the control
efforts of the County Weed Boards and adjacent private landowners. In
many cases the herbicides would be applied by the County Weed District
Crew.
Biological control under Alternative (3) would be the same as under
Alternative (2) above. Leafy spurge defoliating moths and musk
thistle seed-head weevils would continue to be monitored, and new
releases made as available. This would include, but not limited to,
the leafy spurge defoliating moth.
4. Alternative 4 - - Integrated Pest Management (Preferred Alternative)
Alternative (4) would involve an integrated pest management approach
to noxious weed control in coordination with the landowners adjacent
to National Forest System lands. The integrated pest management
approach is a comprehensive systems approach to achieving economical
pest control in an environmentally acceptable manner. The individual
components of integrated pest management include: cultural
(mechanical, manual, prescribed fire) biological, chemical, and
regulatory means. Each of the components may be used alone or
enhanced by combining and timing with other methods to produce a more
effective pest management strategy. Alternative (4) provides for the
application of integrated pest management principles, but emphasizes
chemical control as the primary method.
Cultural weed control under Alternative (4) would include: (1) the
grubbing of weed infestations in wilderness areas, near special
interest plant habitat, and in selected portions of campgrounds (2)
prompt revegetation of soil disturbed by road construction or other
-18-
means, (3) the application of improved grazing practices as range
allotment management plans are implemented.
Biological control under Altrnative (4) would be the same as under
Alternative (2) and (3) above. Spotted knapweed seed-head flies and
musk thistle seed-head weevils would continue to be monitored, and new
releases made as needed. The leafy spurge defoliation moth or other
bio-agents may also be released if available for an appropriate site
on the Forest.
Chemical control under Alternative (4) would be applied on 260 acres
in 1987-1990. the herbicides 2,4-D and picloram would be spot applied
to individual weeds by hand-held nozzle from either backpack or truck
mounted tanks. Some weeds too remote from road access or water would
be treated with solid herbicide in the form of picloram beads.
Details of the herbicide amount, cost, and sites to be treated are
displayed in Appendix 7, A through E.
Education would be a feature of integrated weed management under this
alternative also. An active public information program would be
implemented to inform the public about the effects of noxious weeds.
Wilderness and backcountry visitors and outfitters would be advised of
the possible introduction of weed seed in hay, and encouraged to bring
only clean hay from known weed— free sources (cake or pellets) on pack
trips. Forest Service personnel would also be informed and trained to
identify noxious weeds and to make weed control a Forest objective of
concern to all employees.
-19-
TABLE I
Comparison of Alternatives by Treatment and Cost
Alternative 2
Alternative 3
Alternative
Treatment \J
Cultural &
Chemical &
Integrated
Biological
Biological
Biological
. . Control
Control
Control
Mechanical treatment
1987 Acres
275
0
15 ac.
Cos t
$42,350
0
$2,310
5 year total
Acres*
1,375
0
75 ac.
Cost
$211,750
0
$11,550
Herbicide treatment
0
1987 Acres
0
275 ac.
260 ac.
Herbicide lbs.
0
550 lb.
526 lb.
Cost
0
$18,293
$17,164
5 year total
Acres*
1375 ac.
1,641 ac.
Herbicide lbs.
2750 lb.
2,630 lb.
Cost
$91,465
$ 85,820
Total - 1987 Ac.
275
275
275 ac .
1987 Cost
42,963
$18,293
$19,474
5 year total ac.
1,375
1,375
2 , 7 96 ac .
5 year total cost
$211,750
$91,465
$97,370
* including re-treated acres
1/ Alternative (1) would have no active treatment program, (biological,
mechanical, or chemical) and no direct treatment cost, therefore. Alternative
(1) is not shown in the table. The environmental costs and benefits of all
alternatives are displayed in table II in section D Environmental Consequences.
2/ Alternative (2) assumes annual monitoring of existing populations of
bio-agents and new releases as needed and available, and assumes hand grubbing
and mowing of all infested acres annually during the planning period, with
little or no reduction in area infested by weeds, because of regrowth and seed
germination.
3/ Alternative (3) assumes a reduction in weed infested areas each year as
treatment effectively reduces the populations of weeds, especially spotted
knapweed, whitetop, and thistles. Total acres to be treated will remain the
same in order to include presently invested areas on the forest.
-20-
4/ Alternative (4) includes less acres of chemical treatment than Alternative
(3) because of mechanical treatment on some areas and the weed management
strategy for some populations of containment, rather than control. Biological
control would be applied to the major portion of containment projects with
chemical on portions of the projects. As in Alternative (3), it is assumed
that there is a gradual reduction in weed infested area from year to year.
Total acres to be treated will remain the same in order to include presently
invested areas on the forest.
5/ Biological control monitoring is included in overall maintenace of all
alternative.
6/ During the 1986 season, the only treatment applied with herbicides, will be
done following approval of the EIS.
-21-
/Itemative Conparison - Table on the fol lowing page conpares the effects of implementipg each of the
alternatives. This table is a sunmary of the major effects discussed in the environmental consequences section
and elsewhere in the document.
11VBLE II
EVALUATION CF ALIERNATIVES
Evaluation
Factors
1 Alternative 1
1 No
1 Action
Alternative 2
1 Cultured and
1 Biological
1 Control
Alternative 3
1 Chemical and
1 Biological
1 Control
1 Alternative 4
1 Int^rated
1 Pest Ifet . .
1
1 4*
1
1 3*
1
1 1*
1
1 2*
Noxious Weed
1 Increase to al-
1 Arrest or slow
1 Reduce area
1 Reduce Area
Infestation
1 most double in
1 the advance
1 infested
1 infested at
1 5 years
1
1
1 rapidly
1
1 mod. rate
1
1
1 4
1
1 3
1
1 1
1 2
Forage production
1 Continue to
1 Increase by
1 Increase by
1 Increase by
1 decline on in-
I about 30 AUM
1 72 AUM
1 72 AUM
1 fested acres
1
1
1
1
1
1
Public Health
I
I I
1
1 2
1 4
1 3
and Safety:
1 no hazard
1 Worker Hazard
1 High margin of
1 high margin of
1
1
1 only
1
1 public safety
1
1 public safety
1
1
1 4
1
1 1
1
1 3
1
1 2
Inpact on Native
1 Severe on ***
1 Favors varied
1 Favors grasses
1 Favors grasses
Vegetation
1 acres infested.
1 early succession! redix:ing most
1 reduces broad-
1 Increasing to
1 species on 275
1 broadleafe on
1 leaf on 260 ac
1 **** ac in 5 yrs| ac.
1 1
1 275 ac.
1
1
1
Soil Erosion
1
1 3
1 4
1
1 1
1 2
1 Gradually
1 Imnediate
1 Reduction in
1 Reduction in
1 increasing
1 increase on
1 soil erosion
1 soil erosion
1 anount and
1 area treated
1
1
I size of area
1
1
1
1
1
1
1 4
1
1 1
1
1 3
1
1 2
Inpact on Wildlife
1 Small inpact
1 More favorable
1 Small inpact on
1 Small inpacts
H^itat
1 now, but double
1 than 1 and 3
1 acres treated
1 on acres
1 in 5 years
1
1
1
1
1
1 treated
1
Inpact on T & E
I
1 4
1
1 1
1 2
1 2
Animals
1 Same as £bove
1
1 Same as ^ove
1
1 Same as ^ove
1
1 Same as above
1
Inpact on Bare
1
1 3
1
1 1
1
1 4
1 2
Plants
1 Could effect
1 Could effect
1 Could effect
1 Could effect
1 some
1
1 some
1
1 some
1
1 some
1
Cost to inplement
1
1 1
1
1 4
1
1 2
1
1 3
project short term
1
1
1
1
1
1
1
1
Long term cost to
1
1 4
1 3
1 2
1 1
resource values
1
1
1
1
-22-
*1 , 2, 3, 4 are relative subjective ranking of the alternatives
from most favorable (1), to least favorable (4).
C. AFFECTED EHVIRONMENT
1. Description of the Principal Noxious Weeds
a. Leafy spurge is a very troublesome noxious plant in Montana. It
is a competitive, aggressive perennial which is difficult and expensive
to control. It has deep, tenacious root systems, the capacity to
sprout from root segments, and has underground buds and seeds which can
remain viable for many years. Leafy spurge contains a toxin that can
cause toxic effects in animals from either internal or external
exposure. There is direct evidence that leafy spurge has allelopathic
properties, i.e., the weed releases chemicals that inhibit the growth
of other plants in the same area. It grows any place from the best
agricultural land to rocky slopes and hillsides of low productive
rangeland sites. Infestations range from solid stands where all other
vegetation is virtually eliminated to isolated patches which serve as a
seed source for infestation of additional areas.
b. Spotted knapweed is a biennial or short-lived perennial plant
which reproduces only by seed, yet is able to invade a wide variety of
habitats. Flowers are usually purple and the outer row of bracts under
the head have black, fringed tips. It produces seed even with below
normal precipitation, and then rapidly invades areas where other
vegetation is weakened by drought. The late fall and early spring
growth pattern gives it a competetive advantage over many native
plants. In addition, this weed produces an allelopathic toxin (cnicin)
that inhibits the germination and root growth of native grasses and
trees. This compound may be deposited by knapweed into the soil,
reducing the competition from associated vegetation, suppressing normal
plant succession, and allowing the development and perpetuation of a
weed monoculture of almost pure spotted knapweed. Spotted knapweed is
considered a threat to much of Montanans rangeland and wildlife
habitats. It spreads even more rapidly thatn leafy spurge.
c. Whitetop is a perennial mustard reproducing by seeds and
horizontal creeping roots. It is found along roadsides, waste places
and on rangeland. The stems are erect or spreading^ stout, slender, or
branched stems, slightly to very hairy and 4 to 24 inches tall. The
flowers are white, little more than 1/8 inch wide, each on a stalk
about 1/2 inch long. Whitetop is also referred to as hoary cress.
-23-
d* Musk thistle os a biennial reproducing by seed. It is found in
roadsides, fencelines, pastures, haylands and meadows. The stems are
erect, branched above, hairy, spiny leaves give the stem a winged
appearance; 3 to 5 feet tall. The plant has a heavy taproot. The
flowers are deep rose to purple in color.
e. Canada thistle is an introduced, deeprooted, perennial forb. This
spiny plant reporduces by seeds and creeping rootstocks that spread
laterally 12 to 15 feet in a single year. The shoots form on these
roots each spring. Its grooved stems are 2 to 5 feet tall, and branch
near the top. They are slightly hairy when young, but become covered
with hair as the plant matures. Most of the leaves are oblong,
irregular and have deeply cut, spiny-toothed edges. Flowers are 3/4
inch or less in diameter and are usually purple to rose in color.
f* Palmation to.adfl.ax (Linaria. dalmatica) and Y£j.j,ew. bPadf la;c
( Linaria vulgaris) are introduced wild snapdragons that produce
attractive yellow and orange flowers. They spread readily by a woody,
creeping horizontal root system which enables the plants to survive and
compete with native vegetation on dry, harsh sites. The plants are
very unpalatable to livestock, and difficult to control.
The characteristics of the two weeds of greatest concern on the
Gallatin, spotted knapweed and leafy spurge, are illustrated on the
plates that follow.
2. Location
The proposed project area are located in Gallatin, Madison, Park,
Meagher, and Sweetgrass counties in Montana. All areas are publicly
owned National Forest System land and road right-of-ways managed by the
Gallatin National Forest. Maps and site specific information for each
site can be found in the Supervisor office, Gallatin National Forest.
Site specific locations are listed in Appendix 7 A through E.
Project Site General Descriptions
Categories of project environments that encompass all areas proposed for
treatment are:
a. Forest Roads and Trails - Noxious weeds in this environment are
confined primarily to areas where soil disturbance has provided an
adequate seed bed. Cut and fill slopes are the primary areas of
concern.
b. Recreation Sites - Areas included in this listing are
trailheads (end of road facilities included), interpretive
visitor information centers.
campgrounds ,
sites, and
-24-
c. Timber Harvest Areas - Includes temporary roads, skidroads,
firelines and landings. Soil disturbance inherent found with this type
of activity provides the proper environment for establishment of
noxious weeds.
d. Administrative Sites - Ranger stations, guard stations, and horse
pastures are included under this project environment.
e. Mountain Rangeland - Primarily grassland vegetative types often
intermixed with patches of timber including aspen, juniper, lodgepole
pine, and Douglas fir. Domestic livestock production is generally
associated with this project environment.
-25-
p",T''T"ir"i II v^i rgi
»r •'»-
LEAFY SPURGE (Euphorbia
B. flower cluster (X2.5)
(X6)
esula L. ) : A. Habit
; C. capsule (X2.5);
(XO . 5) ;
D . seeds
-26-
< ■' » aiiif
M.b.i.i -lu-4.
|\»* S'—' • ’
iiiLiiLiiliiiluj ' ' '
SPOTTED KNAPWEED (CojiUlM.ea Vvoi’-'o i sk^" t lowc r
(X0.5); B. leaf (Xl); C. flowci head (X.), D.
(X3.5); E. aclicncs (X'l)
rk “T
3.
Climate and Air Quality
The climate for the Gallatin National Forest is typical of the Rockies
east of the jContinental Divide. It is characterized by warm summers
with most of' the precipitation falling as rain from April through the
end of June, or in the high elevators as winter snows. Average annual
precipitation ranges from 30 to 40 inches in the mountainous areas to
15 to 20 inches in the foothills of the forest.
Air quality in the EIS area is good overall. Most of the EIS area is
Class II, which allows moderate deterioration of air quality. The
Clean Air Act Ammendments of 1977 contain provisions to ensure that air
quality does not deterioraze in areas with clean air.
4. Geology and Topography
Much of the Forest's present geology is accounted for by episodes of
mountain building, which occured about 60 million years ago. All but
one of the Gallatin's mountain ranges were created by the over
thrusting of rock strata. One range - - the Crazy Mountains ~ - was
formed by a massive domal uplift. '
The topography consists of rolling foothills and level benches moving
up to steeper slopes and ridges.
5. Soils
Broad areas of clayey soils exist in the Absaroka mountains, Bridger -
Bangtail mountains. Upper Gallatin Canyon, and parts of the Gallatin
and Madison ranges. Other soils on the Forest are relatively
coarse~textured , such as those found in the Beartooth mountains. Crazy
mountains, the West Yellowstone sands area, and the Spanish Peaks.
A more detailed explanation of the soil types found at each control
site can be found in the interim draft report, soil survey of Gallatin
Forest Area Southwestern Montana, April 1984.
6. Water Resources
The Gallatin National Forest provides approximately 2,028,000 acre-feet
of water to the Missouri River drainage during an average year. The
quality of water being produced on the Forest of present is very high,
as evidenced by the headwaters of three major Blue Ribbon trout streams
on the Gallatin National Forest - - the Madison, Gallatin, and
Yellowstone rivers.
In these areas, most streamflow results from spring snow melt, and
local surges result from summer thunderstorms.
-28-
7. Vegetation
The Gallatin national Forest supports forests on upperslopes, alpine
tundra above timberline, conifer forests, aspen, grasses, mountain
shrub and sagebrush - grass vegetation. Major tree species include
lodgepole pine, Douglas fir, ponderosa pine, subalpine fir, whitebark
pine. Limber pine, willow, aspen and alder are also common. The areas
predominant shrubs are common snowberry, big sagebrush, cur leaf
mountain mahogany, serviceberry , chokecherry, and ninebark. Major
grass species include bluebunch wheatgrass, Idaho fescue, Kentucky
bluegrass, alpine grasses, pinegrass, mountain biome, timothy, and
needlegrasses. There are no known threaten or endangered species
located on the forest.
8. Animals
Livestock
Currently on the Gallatin National Forest there are 39,150 animal unit
months (AUM's) being grazed per year. This amount is being taken
primarily by cattle, then sheep and horses. (GNF Draft Forest Plan
1985)
Wildlife
The EIS area encompasses a variety of wildlife habitats. Wildlife
diversity and abundance is high on the Gallatin National Forest.
Biggame species found within the EIS area include: elk, bighorn sheep,
muledeer, whitetailed deer, moose, black bear, grizzly bear, mountain
lion.
Upland game bird species found within the EIS area include blue,
Franklin, ruffed, and sharptail grouse. Hungarian partridge are also
found within the area.
Waterfowl are found in isolated instances within the control areas but
in very small numbers during the periods of noxious weed control.
Fish
Many game fish species inhabit the EIS area, including cutthroat trout,
rainbow trout, browntrout, brooktrout, grayling, and whitefish.
Trout spawn in both the major rivers and tributary streams. Rainbow
and cutthroat trout spawn in the spring. Brooktrout and browntrout
spawn in the fall.
Threatened and Endangered Animals
The EIS area provides habitat occupied by two endangered species
bald eagle, peregrine falcon, and one threatened species - - grizzly
bear.
-29-
9.
Cultural Resources
The historic and prehistoric sites that exist on the Forest are
protected by the National Historic Preservation Act and other
mandates, ^rveys conducted have uncovered several hundred sites, 53
of which are eligible for inclusion on the National Registry of
Historic Places.
There is no forseeable conflict between noxious weed control and the
cultural resources on the Forest at this time.
Visual Resources and Recreation
The Gallatin National Forest ranks high in visual resources and
recreational values, noxious weed control is being alone on road
right-of ways throughout the EIS area and at approximately 10
recreational sites, these being end of road facilities, trailheads, and
campgrounds .
10. Wilderness and Special Areas
There will be no chemical control of noxious weeds within the
Absaroka-Beartooth or Lee Metcalf Wilderness on the Gallatin National
Forest unless approved by the Regional Forester.
Economic Conditions and Social Environment
Contract spraying has provided income to individuals who have had
successful bids for weed spraying on the Gallatin National Forest.
County weed control programs are also supplemented with Forest Service
funds for their work on National Forest right-of-ways in certain
locations .
If the noxious weed control program were curtailed economic losses
would be in the form of (1) Loss of grazzing capacity on rangelands
infested with noxious weeds on the National Forest. (2) Loss of
recreational use at trailheads and campgrounds infested and overrun
with noxious weeds and (3) loss of wildlife habitat.
As weeds spread onto private rangeland economic losses would be
proportionate to investation levels.
A significant social issue related to the Gallatin National Forest's
weed control program is possible public disagreement about the use of
herbicides and the effectiveness of alternative treatments.
Opponents of herbicides may see the Forest Service as having a bias in
favor of herbicides. They could see the Forest Service as not taking
serious concern and research into what they perceive as more legitimate
control measures. The proponents of herbicide use could see the Forest
Service looking for unnecessary alternatives to what they believe to be
a demonstrably safe and effective means for controlling noxious weeds.
-30-
Some people are concerned with; (1) the spread of noxious weeds from
National Forest lands onto private or state lands; (2) the economic
losses from this encroachment; and (3) the effects of noxious weeds on
native vegetation. Public interest also exists in cooperative programs
of weed control. Concern over the spread of noxious weeds is expressed
by county and state laws enacted to control noxious weeds.
Another segment of the public is concerned with not having control over
their larger environment, including the management of National Forest
lands. There is a growing sense that the nonprofessional public has a
legitimate interest in how these land resources are managed. The
traditional attitude of leaving resource management to the
"professionals" is becoming less prevalent, with more people wanting
some say in how professionals do their job.
D. ENVIRONMENTAL CONSEQUENCES GF ALTERNATIVES
1 . No Action
Left unchecked the noxious weeds will continue to spread on the
Forest. It appears that knapweed has been spreading in Montana at an
average annual rate of about 27% since 1920 (Montana State University,
Oct. 1983). At this rate the Forest acres infested by spotted knapweed
will increase from 200 dense acres in 1985 to 659 acres in 1990.
Spread of leafy spurge is estimated to be about 12% per year (Lewistown
District, BLM, 1985). At this rate, the area infested on the Forest
will increase from 251 dense stand acres in 1985 to 440 acres in 1990.
Whitetop and thistle with a combined infestation of 850 acres is
estimated to spread at about 4% per year, which should result in about
1,033 acres infested by 1990. Therefore, the total weed infested acres
of these species is likely to increase from 1,301 in 1985 to a level of
2,132 acres in 1990; almost double the current level. Left unchecked,
the cost of weed control could double in 5 years.
There are 300 acres of open range with heavy knapweed and leafy spurge
infestations that will not be treated under this alternative. Assuming
an average potential carrying capacity of 2.5 acres/AUM (0.4 AUM/ac.)
when the weeds cause a 60% loss of forage there are 0.24 AUM s of
forage lost per acre or 72 AUM's on this range that will not be
recovered (Montana State University, April, 1983). Forage production^
would decline on the newly infested range areas at a rate of about 10%
per year starting in the second year of infestation. By the end of the
10th year following invasion, the knapweed density would approach 90%
with little forage available for livestock (Montana State University,
December 1 984) .
The allelopathic toxins in leafy spurge and spotted knapweed often
result in the development and perpetuation of a weed monoculture. The
most drastic biological effect that this could have would be the
elimination of rare plant species (Montana State University, December
1984). At present there are no known plant species in or adjacent to
the project area classified under the Endangered Species Act. However,
there are plants of special interest present that are listed on the
-31-
"Preliminary List of Vascular Plants of Rare and Undetermined Status
for the State of Montana." (Lesica, Peter, et. al. June 1982).
Appendix 10, file letter from Steve Shelly, Botianist, Montana Natural
Hertiage Program. Some of these plants could eventually be eliminated
from the area by the severe biological competition of knapweed and/or
leafy spurge, although there is no immediate threat.
As knapweed and leafy spurge increase and crowd out more favorable
forage plants the habitat for may wildlife species would likely
deteriorate. The project area includes the occupied habitat of the
threatened grizzly bear, and important seasonal ranges of elk, deer,
bighorn sheep, black bear, mountain grouse, and many other wildlife
species. There is some evidence that deer and elk may feed on young,
green knapweed plants. However, not controlling these noxious weeds
could result in a long-term decline in the habitat of the grizzly bear
and many other wildlife species, especially big game winter range.
However, the present impact is not significant because of the scattered
nature of the infestations.
Impacts to fisheries would be in the form of potential increases of
sedimentation and decreases of bank stability associated with the
noxious weeds crowding out more desirable vegetation. These impacts
stem from the decrease in streamside vegetation that function as a
filter for sediments coming from overland flow. The extensive root
systems developed by grasses, sedges and shrubs along streambanks is a
very important factor in streambank stability.
There would be no human health risk associated with the No Action
alternative.
2 . Alternative C 2) . CyJturaJ._ and. Pi-glogical. Coutxgl
Results from a study of cultural practices for leafy spurge in 1983
showed that hand pulling could be an effective way to control small
infestations of leafy spurge for one year. Seed production can be
eliminated and regrowth is severely stunted, which will slow the
advancing infestation. This method of control would be best suited to
small patches along waterways where herbicide use is restricted and
where leafy spurge seed production must be eliminated to prevent
dispersal by water (Montana State University, Aug. 1984). However,
because the roots of leafy spurge may produce vegetative buds as deep
as five feet below the surface, it is impractical to fully dig the
plants up to prevent resprouting. Eradication of leafy spurge with
mechanical methods requires 2 to 3 seasons of intensive cultivation
with a duckfoot cultivator 4 inches deep every 21 days during the
growing season (Sonder, Leslie, 1969).
The initial cost of mechanical treatment $42,000 in Alternative (2) is
238% more than for chemical treatment in Alternative (3) $18,000. In
addition, the cost of needed follow-up mechanical treatment in
subsequent years $43,000 would be two or three times the needed
follow-up chemical treatment ( $1 8-$l 9 ,000) .
-32-
Soil disturbance and erosion would increase more under mechanical weed
control than under Alternatives (1), (3), and (4). Alternative (2)
would have less impact on plant species composition, as fewer
non-target plants would be affected. Mechancial treatment would
present the least risk to special interest plants in the area.
Wildlife habitat would benefit more from mechanical treatment than no
control or chemical control.
The human health risk associated with the mechanical treatment
alternative would be the safety hazard for workers using small hand
tools in grubbing out weeds, and for operating , mowing, and tillage
equipment. There would be little or no hazard to the general
population.
Mechanical treatment of weeds would improve the forage resources for
livestock in the long run. However, where soil disturbance is great,
the resulting initial increase in plants would be largely "pioneer"
weedy broadleaf species replacing the noxious weeds. Follow-up efforts
would require artificial seeding of desirable forage plants on highly
disturbed sites, such as tilled land. There would be a high risk of
the reinvasion of noxious weeds or other undesirable plants on the
disturbed soil. Overall the forage improvement under this alternative
would be intermediate to Alternatives (1), (3), and (4).
3. Altprnative (3) Chemical and Biological Control
Research shows that the application of herbicide can provide effective
control of the target weeds. Residues of the herbicide picloram remain
in the soil for up to three years and will kill seedlings for two or
more years after application, depending on soil texture. Experimental
results of 99-100% control of both knapweed and leafy spurge the first
year of treatment have been demonstrated. However, it is necessary to
follow-up with re-treatment for several subsequent years because of
persistent seed germination and deep dormant buds that survive the
herbicide treatment and residual effect. 2,4— D can be effective in
controlling leafy spurge and knapweed where picloram is restricted, but
annual applications of 2,4— D would be required indefinitely to control
leafy spurge (Messersmith , C.G., 1983 and Montana State University,
Dec. 1984).
The cost of chemical treatment is high ($18,000) but is about 40% of
the cost of mechanical treatment ($42,000).
The herbicides, picloram, and 2,4-D, are selective in their action.
Most broadleaf herbacious plants, wood shrubs, vines, and trees are
susceptible to toxic response to these chemicals. However, most
grasses are resistant and show little effect (Dow Chemical Company,
1983). As a result of this selective action, herbicide treatment
releases grasses from the competition with herbacious plants and
results in a rapid increase in grass density and production. Following
herbicide treatment on the project area, forage production would be
rapidly improved on 300 acres of rangeland. It is estimated that
forage production would increase by 72 AUM.
-33-
Sites to be treated on the Forest with herbicides are classified into
four types:
1. Rights-of-way - Treatment occurs near a road right-of-way. Often
soils along rights-or way are recently distrubed. Treatment of weeds
will provide existing grass species opportunity to spread and thrive.
Herbicide application involves spot applications within 10-30 feet of
the road. 70 percent of the sites to be treated are rights-of-way
type.
2. Riparian - This indicates treatment occurs near a stream, lake,
wetland, meadow, etc. Mitigation measures in section E of this chapter
are prescribed to prevent herbicide application to any standing or
running water.
3. Open Range - This indicates that treatment occurs on general open
range or forest lands. The largest open range site on the Gallatin
Forest scheduled for treatment contains about 40 acres of noxious weed
infestation scattered over an area of 2600 acres. Most treatment sites
are an acre or less in size.
4. Occupied Site - This indicates that treatment occurs on a human
occupied site such as a campground or ranger station. Mitigation
measures for herbicide application are listed in section E of this
Chapter. Appendix 8A provides and assessment of the human health risks
for all project typers. Appendix 7 lists each site by type, weed
species and acres to be treated.
-34-
Where herbacious plants and shrubs are important wildlife habitat
components, herbicide treatment of intermingled noxious weeds could
cause a deterioration in habitat conditions by reducing plant
diversity* However, where a large monoculture of noxious weeds exists
the herbicide treatment would improve plant diversity. Since most of
the present weed infestations are small, isolated patches, or
intermingled with other vegetation the chemical treatment is expected
to cause only a short-term decline in wildlife habitat cover and
forage *
The herbicides that are proposed for use in chemical control (2,4-D and
picloram) both have a low level of toxicity to birds and mammals.
Because of this low toxicity, and the procedure of spot application,
the risk of any adverse effects on wildlife species is very low.
Threatened grizzly bear occupied habitat is involved on 65 net acres
that would be treated with herbicides. However, because the treatment
is largely roadside right— of— way and trailheads, the area affected is
of low habitat effectiveness for the grizzly bear. Therefore, no
adverse effects would be expected on the grizzly bear or its habitat
based on the biological evaluation Appendix 2A.
The proposed chemicals are toxic to fish, however, toxicity is directly
related to the concentration levels that enter the water. Herbicides
that enter into a small stream of less than 5 cubic feet per second
(cfs) of water will have a greater impact than they will in a larger
stream with 20-30 cfs. Concentrations of herbicide in water, even
under reasonable foreseeable case conditions, would be below
milligram/liter , which is 0.1 ppm (See section 2. 4. 6. 4 of appendix
8B). Research on the toxicity of 2,4-D and picloram, show that the
LC for rainbow trout is 100 parts per million (ppm) and 50-58 ppm
respectively. LC is the concentration of pesticide in the water
necessary to kiirW, of the fish population. The proposed projects
that are near streams should have little potential effect on the
fisheries because of the high volumes of water and low rates of
application being applied (Walch 1985 and Hancock 1985).
Although there are no known plant species in or adjacent to the project
area classified under the Endangered Species Act of 1973, there are
rare plants of limited distribution present which are subject to
elimination by herbicide treatment over relatively small areas of
habitat (Lesica 1982). Some of these special interest plants could be
eliminated by herbicide drift or movement of picloram in the soil.
Picloram is long lasting, potentially mobile in the soil, and is highly
toxic to both weeds and desirable broadleaf plants alike. There is a
high risk of killing some special interest plants, under this
alternative, since herbicide would be applied adjacent to rare plant
habitat.
The human health hazard associated with the application of herbicides
is a major issue* The human health hazard for Alternative 3 is similar
to Alternative 4. For a description of the human health risks
associated with herbicide treatment refer to Appendices 8A and 8B and
-35-
the narrative discussion of environmental consequences for Alternative
4 below. Since the herbicide being applied is greater in Alternative 3
than in Alternative 4, the human health risk is also considered
greater, although the reasonable foreseeable case scenario is
essentially the same in both alternatives.
4. Alternative (4 ) Integrated Pest Management (Preferred Alternative)
The environmental consequences of the integrated pest management
alternative include a combination of the effects discussed above in
Alternatives 1-3, differing only in the degree to which each method is
applied .
All weed treatment in the wilderness would be by hand grubbing. Soil
disturbance and erosion resulting would be negligible for this
treatment. Mechanical treatment by hand grubbing of these selected
areas would minimize the risk of exposing rare plant habitat to
herbicide, and reduce herbicide treatment in campgrounds to only dense
weeds that are impractical to mechanically hand grub. The proposed
mechanical treatment could potentially disturb unidentified cultural
resources (historical or prehistorical) on or near the ground surface.
Because of the scattered, low density of weeds on the acres scheduled
for mechanical treatment, the probability of affecting cultural
resources is low. Cultural control would be applied to a small 15
acres in 1987) area of scattered weed infestations.
The cost of control in Alternative 4 is lower than full cultural
treatment in Alternatives 2 and 3 (see Table 1 - Comparison of
Alternatives) .
Sites to be treated with herbicides are classified into four types as
described in Alternative 3 and listed in Appendix 7.
The impacts of herbicide treatment on wildlife, fishery habitat and
threatened and endangered species would be similar to the consequences
described in Alternative 3, but with a somewhat lower impact because
the amount of herbicide proposed is less in Alternative 4.
The human health hazard associated with the application of herbicides
is a major issue with certain segments of the public. To investigate
this risk, the Forest Service reviewed the hazards of applying commonly
applied herbicides including picloram and 2,4-D. The results of this
assessment were published in August 1984 in EegJti.CJ.de. PackgrPUIid
Rrntements. Volume I. Herbicides. Agriculture Handbook No. 633 (USDA
Forest Service. 1984). These background statements provide a
comprehensive review of the available information concerning the use,
chemistry, toxicology, environmental fate, and comparative hazard of
the herbicides in forest applications. The toxicology data in this
background statement is presented for invertebrates, fish, birds, and
mammals. Mammalian toxicology data is further divided into acute,
subchronic, chronic, reproductive toxicity, mutagenicity, and
carcinogenicity (see Appendix lb Glossary).
-36-
More specific worst-case risk analysis for projects in the Northern
Region was completed in 1985 and revised in 1986. This assessment is
contained in the document titled Analysis, of.
USDA. Forest Service Use of Herbicides to Control.
Northern Region . This document is included as Appendix 8B of the
Environmental Impact Statement. This document analyzes the risk to
human health resulting from the application of various herbicides
(including picloram and 2,4-D) on noxious weed project models similar
to the proposed projects on the Gallatin National Forest.
Finally* an analysis specific to the proposed Alternative 4,
application of herbicide on the Gallatin National Forest, was
conducted. This analysis is contained in Appendix 8A titled Human
Hpalth Risk Analysis for Proposed. Hexkicide. .Spray Programs to Control
Nnxinu.s Weeds on. the Gallatin National Forest . The Gallatin National
Forest analysis is based on the Regional analysis ard assesses
potential impacts of the specific sites proposed for spraying on this
Forest. The following paragraphs summarize the salient points of the
site-specific analysis.
In reality, members of the general public are unlikely to be exposed to
herbicide from most projects proposed on the Gallatin National Forest.
Most herbicide application occurs on remote sites and at distances of
over a mile from the nearest residence. Visitation of these sites
would be extremely rare. An exception would occur with the proposed
application of a small amount of herbicide (about 5 pounds active
ingredient) to five trailheads, 3 campgrounds and the visitor center at
Earth Quake Lake. In all cases, these facilities would be closed
during spraying and the spray area closed for two days after spraying.
The doses to workers and members of the general public are calculated
using various conservative assumptions that overestimate impacts. For
example, open-range projects are assumed to be within 200 meters
(one-eighth mile) of a residence when, in fact, residences are
typically further than a mile from open-range projects and none are
closer than one-quarter mile.
The calculated worst-case doses are compared to the pesticide
Acceptable Daily Intake (ADI) as determined by the U.S. Environmental
Protection Agency. The ADI is defined as the dose of a pesticide that
could be taken daily for a lifetime without adverse health impacts.
The ADI is determined by dividing the dose level shown to have no
effect on test animals (the no-observed-effect level or NOEL) by a
safety factor. A safety factor is used to allow for differences
between test animals and humans, to account for test methods usesj and
to allow for more sensitive humans. Safety factors of 100 or greater
are typically used; thus for 2,4-D the ADI is equal to the NOEL divided
by 100.
With only three exceptions, all possible doses to the general public
are below the ADI's for 2,4-D and picloram. The dose could exceed
slightly the 2,4-D ADI if a person ate one-half pound of wild food
directly sprayed with 2,4-D. This dose must be considered a
low-probability event considering the remote location of spray sites
-37-
and the fact that wild foods such as berries would not ripen for
several weeks or more after spraying. Direct spraying of berry bushes
would also probably "burn" the vegetation and prevent fruit
development.
The worst-case dose could slightly exceed the ADI for 2,4-D if an
individual (with bare legs, arms, hands, face, and neck) stays within a
meter of spraying. Again, this scenario would be highly unusual.
In the event of a major spill of herbicide into a drinking water
source, a person drinking a large amount of water (e.g., over 2 quarts
for an adult) could receive a dose that slightly exceeds the ADI.
However, a truck accident resulting in the spill of herbicide is a very
unlikely event. A major spill into water is even more unlikely.
Worker doses are likely to be much higher than general population
doses. All worker 2,4-D dose estimates are above the ADI for 2,4-D.
Worker picloram dose estimates are above the picloram ADI if worker is
assumed to wear little protective clothing and to apply pesticides with
sloppy techniques.
Although worker health can be adequately protected during picloram
application by requiring use of protective clothing (long sleeved
shirts, gloves, hats), 2,4-D exposure could exceed the ADI for projects
requiring large daily applications. The significance of this
exceedance requires further consideration particularly since the ADI
assumes a lifetime of doses and workers would be exposed for a maximum
of 3 weeks.
Under normal protection scenarios, worker dose is estimated to be 11 to
33 times less than the NOEL based on animal tests. At 2,4-D dose
levels above this NOEL, test animals (rats) began to exhibit changes in
kidney function. These effects ceased when dosing ceased. Since
humans can be 6 to 12 times more sensitive to chemicals than test
animals (see Section 2.5 of the Northern Region Risk Analysis in
Appendix 8B) , some workers could experience short-term effects on
kidney function although symptoms would not be obvious over the typical
applicaiton period. Again, the importance of careful applicaiton
techniques and use of protective clothing must be emphasized to
workers .
Although the evidence on the cancer-causing potential of 2,4-D and
picloram is ambiguous, both compounds are assumed to cause cancer. The
estimated lifetime cancer probability for a member of the general
public exposed to 2,4-D or picloram is less than one chance in ten
million even assuming worst— case doses from five consecutive years of
spraying. Worker cancer probabilities are on the order of one to five
chances in a million.
The linear cancer model used in the analysis estimates the upper bound
of the cancer risk and generally overestimates risk. Therefore, the
cancer risk as estimated by the risk analysis has a built-in margin of
safety for humans. The calculated risks are below those associated
with natural background radiation that humans encounter on a daily
-38-
basis. This level of cancer risk is accepted by the Food and Drug
Administration and the Environmental Protection Agency.
The possible cumulative and synergistic impacts of Forest Service
spraying, in> addition to impacts from other spraying, are discussed in
Section 2.8 of the Northern Region Risk Analysis in Appendix 8B. Given
the widely scattered nature of these herbicide treatments (261 acres
treated on a 1.8 million acre National Forest), such effects are not
reasonably expected.
E. MANAGEMENT CONSTRAINTS
This section lists the constraints that must be applied to approved projects.
1. All herbicide application workers must be advised explicitly of
the hazards of these chemicals and instructed in the careful
herbicide application techniques, so as to reduce dose levels
below worst-case values assumed in the risk analysis.
2. Appropriate personal protective equipment will be included in
developing project safety and health analysis (FS 6700—7) for
Forest Service applicators (see Health and Safety Code Chap. 9-10
FSH 6709.11) .
3. Pesticides must be applied under the supervison of a licensed
pesticide applicator under the laws of the State of Montana. To
apply picloram, the applicator must be licensed for restricted use
herbicides. Pesticides must be applied consistent with the
instructions on the label (see Appendix 9, A-C) .
4. No herbicides will be applied within wilderness areas, proposed
research natural areas, or areas occupied by rare plant species
unless approved by the Regional Forester . Weed control in these
areas will be by cultural methods only (hand grubbing, etc.).
Sufficient buffer zones (at least 50 feet) will be established to
prevent herbicide drift or subsurface movement into these areas.
5. The use of herbicide to control weeds in campgrounds will be
^gg^j-£^ted to 2,4— D only. Public notification and signing will
precede the application of herbicide, and the treated areas will
be closed to public use for two days following treatment. Areas
adjacent to water wells, and other selected areas within the
campgrounds will be mechanically treated by hand-grubbing .
6. No herbicide will be applied directly to any standing or running
water. Picloram will not be sprayed within 50 feet of a stream,
pond or other water source, or within the normal high water level
of streams or ponds, whichever is the greater distance. Picloram
will not be sprayed, or allowed to drift onto the inner banks of
ditches or water channels that carry water.
7. The location of the inventoried noxious weed infestations
scheduled for mechanical treatment will be compared with the
Forest cultural resource site atlas in consultation with the
-39-
Forest Archeologist prior to treatment. If it is determined that
there is a probability of cultural resource disturbance, then,
on-site cultural inventory will be conducted prior to treatment.
If cultural resources are noticed during mechanical treatment, the
work will be stopped until the Forest Archeologist can conduct a
cultural resource evaluation.
8. If herbicides are applied in municipal watersheds constraints in 6
above will be used.
F. LIST OF AGENCIES, ORGANIZATIONS, ELECTED OFFICIALS AND INDIVIDUALS TO WHOM
COPIES ARE SENT
Elected Officials:
Max Baucus, U. S. Senator
Ron Marlenee, U.S. Congressman
Ted Schwinden, Governor of Montana
Federal Agencies:
Animal and Plant Health Inspection
Service
Bureau of Indian Affairs
Bureau of Land Management
Environmental Protection Agency
Federal Highway Administration
Fish and Wildlife Service
Missouri River Basins Commission
National Park Service
Yellowstone National Park
State Agencies:
Cooperative Extension Service
Dept, of Fish, Wildlife and Parks
Dept, of State Lands
State Clearinghouse
County Agencies:
Gallatin County Weed District
Sweetgrass County
Meagher County Weed District
John Melcher, U.S. Senator
Pat Williams, U.S. Congressman
Forest Service
Northern Region Office
Beaverhead National Forest
Custer National Forest
Flathead National Forest
Helena National Forest
Intermountain Forest and Range
Experiment Station
Office of Environmental Review
Soil Conservation Service
Department of Agriculture
Dept, of Health and Environmental
Natural Heritage Program
Park County Weed District
Madison County
Organizations, Associations, Clubs, etc.
Audubon Society
Ducks Unlimited
Yellowstone Ecosystem Committees
Meagher County Livestock Growers Assoc.
Meagher County Stockgrowers
Montana Wildlands Coalition
National Wildlife Federation
Defenders of Wildlife
Environmental Library, U of M
Idaho National Resource Legal
Foundation, Inc.
Montana Wilderness Association
Montana Stockgrowers Association
Nature Conservancy
-40-
Rocky Mountain Front Advisory Council Sierra Club
Western Environmental Trade Assoc Brackett Creek Grazing Assoc.
Wildlands Resource Association
G. LIST OF PREPARERS*
1. Charles Sundt
Range Conservationist, Bozeman Ranger District, Gallatin National
Forest, Bozeman, Montana.
2. Edward C. Monnig
Ecologist, Cooperative Forestry and Pest Management, Northern Region,
Missoula, Montana
3. Thomas D. Osen
Range Technician, Bozeman Ranger District, Gallatin National Forest,
Bozeman, Montana
4. Robert L. Dennee
Forester, Public Information Officer, Gallatin National Forest,
Bozeman, Montana
5. Richard Inman
Range Wildlife Staff Officer, Gallatin National Forest, Bozeman,
Montana
6. John Sandmeyer
Planning Staff Officer, Gallatin National Forest, Bozeman, Montana
-41-
H. APPENDIX
1. Reference
a. Bibliography
b. Glossary
2. Resource Specialist Reports
a. Biological Evaluation for Noxious Weed Plan
b. Fisheries Biologist Report
3. Proposed Mechanical Treatment by Districts, Alternative 2
4. Proposed Ground Application of Herbicides by Districts, Alternative 3
5. Proposed Integrated Treatment by Districts, Alternative 4
6. Estimated Cost of Noxious Weed Control by Method of Treatment and
District.
7. Detailed Listing of Project by District (Available at Gallatin
National Forest Supervisor's Office)
a. Big Timber Ranger District (D-1)
b. Livingston Ranger District (D-2)
c. Gardiner Ranger District (D-3)
d. Bozeman Ranger District (D-6)
e. Hebgen Ranger District (D-7)
8. Human Health Risk Analysis
a. Gallatin National Forest
b. Northern Region (Available upon request)
9. Pesticide Labels
a. Tordon 22k (Picloram)
b. Tordon 2k pellets (Picloram)
c. 2,4-D Amine
-42-
APPENDIX la BIBLIOGRAPHY
Bureau of Land Management, 1985
Northwest Area Noxious Weed Control Program USDI, BLM, Final
Environmental Impact Statement
Custer National Forest, February 1986
Noxious Weed Treatment Program. Draft Environmental Impact Statement
Dow Chemical Company. 1983.
eptibility to Picloram,
Gallatin National Forest, 1985
Draft Environmental Impact Statement. Forest Plan. USDA. Forest Service
Howarth, Neil, 1983
Noxious Farm Weeds^ Estimated Acreages on the Gallatin National Forest.
USDA Forest Service
Lesica, Peter, et al.June 1982.
? pel ipin&FY-h i st_ of Vascular Plants of Rare and Undetermined Status for
the State of Montana. Compiled by the Montana Rare Plant Project,
Department of Botany, University of Montana.
Lewis and Clark National
Forest, 1985
_ EDyironm£Pffll_ j
USDA, Forest Service.
Lewistown District BLM. 1985.
Programmatic Environmental Assessment for Containment/Eradication of
Bureau of Land Management, Montana, Lewistown District.
Mass, Fred. 1984.
Knapweed that is not Contained, op. Ygur. Forest - Rangeland Means Loss
of ; Leaflet by Montana Knapweed Action Committee.
Messersmith, C.G., 1983.
North Dakota Farm Research Biomonthly Bulletin Vol. 40, No. 5, March -
April, 1983.
Montana State University. August 1984.
Leafy Spurge News. Issue #3 Volume V. Plant and Soil Science
Department. MSU.
Montana State University. December 1984.
Proceedings of the Knapweed Symposium. Bulletin # 1315. Plant and
Soil Science Department and Cooperative Extension Service MSU.
Montana State University. December 1984.
The Potential Cost of Spotted Knapweed to NoPfflPfl. PflPee. Upers Bulletin
#1318. Cooperative Extension Service.
-1-
Montana State University. April 1983.
Knapweed - Its Cause. Effect, and Spread in Montana. Circular 307.
Cooperative Extension Service MSU.
Montana State University. October 1983.
Knapweed Update. Issue # 1> Volume I Newsletter of Plant and Soil
Science Department, MSU.
Bonder, Leslie. 1969
Leafy Spurge. Leaflet # 174. Cooperative Extension Service, Montana
State University.
Spoon, Charles W. 1983.
Noxious Weeds op the Lplp National Forest. USDA Forest Service
Situation Analysis Staff Paper.
* USDA Forest Service. August 1984.
Handbook Number 633. 2,4-D pp. D1 - D181; Dicamba pp. Di 1 - 74;
Picloram pp. PI -87.
Walch, Len. 1985.
Official correspondence (2630) concerning herbicide and fish. Helena,
MT July 1, 1985 (Appendix 3b).
*These materials are included by reference. Copies of this material is
available in the Forest Service office in Bozeman, Montana.
-2-
APPENDIX lb
GLOSSARY
ACCEPTABLE DAILY INTAKE (ADI) ; The maximum dose of a substance that could be
taken daily for a lifetime without adverse health impacts. The ADI is
determined by dividing the dose level shown to have no effect on test animals
(the no observed effect level of NOEL) by a safety factor used to allow for
differences between test animals and humans, to account for test methods used,
and to allow for more sensitive humans. Safety factors of 100 or greater are
typically used (ADI = NOEL/Safety Factor).
ACID EQUIVALENT (a.e.): The amount of active ingredient expressed in terms of
the parent acid.
ACTIVE INGREDIENT (a.i.): The agent primarily responsible for the intended
herbicidal effects of a product.
ADJUVANT: Substance added to a spray to act as a wetting or spreading agent,
sticker, penetrant, or emulsifier in order to enhance the physical
characteristics of the herbicidal materials.
ADSORB: Adherence of a substance to a surface.
AESTHETICS: Evaluations and considerations concerned with the sensory quality
of resources (sight, sound, smell, taste, and touch) and especially with
respect to judgment about their pleasurable qualities.
ALLEOPATHIC: Pertaining to the suppression of growth of one plant species by
another through the release of toxic substances.
AMINE: Any of a group of chemical substances derived from ammonia in which
one, two, or three hydrogen atoms have been replaced by one, two, or three
hydrocarbon groups.
ANIMAL UNIT MONTH (AUM) : The amount of forage required to sustain one mature,
1000 pound cow or the equivalent for 1 month.
ANNUAL PLANT: A plant that completes its life cycle within a year.
BIENNIAL PLANT: A plant that completes its life cycle in 2 years.
BIOACCUMULATION: The accumulation of a substance in the biological componets
of an ecosystem.
BIOASSAY: The testing of the effects of chemical substances on live organisms
under controlled conditions.
BIOLOGICAL CONTROL: The use of natural enemies to attack a target plant,
retard growth, prevent regrowth, or prevent seed formation.
-1-
BROWSE: That part of a leaf and twig growth of shrubs, woody vines, and trees
on which browsing animals can feed; to consume browse.
BUFFER (STRIP OR ZONE): A zone left untreated with herbicide (at the outer
edge of a treated area or along streams) as protection against the effects of
treatment.
CARCINOGEN: A substance producing or inciting cancer.
CHEMICAL DEGRADATION: The breakdown of a chemical substance into simpler
components through chemical reactions.
CHRONIC TOXICITY: The poisoning effects of a series of doses applied over a
long period.
CONCENTRATION: The amount of active ingredient or herbicide equivalent in a
quantity of diluent, expressed as Ib/gal, ml/liter, etc.
CONGENITAL: Existing at birth but acquired in the uterus rather than
inherited .
CONTROL: Reduction of a pest problem to a point where it causes no significant
economic damage.
CRITICAL HABITAT: (1) Specific areas within the habitat occupied by a species
at the time it is listed under the Endangered Species Act where there are
physical or biological features (i) essential to the conservation of the
species and (ii) that may require special management considerations or
protection, and (2) specific areas outside the habitat occupied by the species
at the time it is listed upon the determination by the Secretary of the
Interior that such areas are essential for the conservation of the species.
DNA (DEOXYRIBONUCLEIC ACID): Any of the nucleic acids that are the molecular
basis of heredity in many organisms.
DOSAGE: The regulation of doses; how often and for how long.
DOSE: The amount of chemical administered at one time. A given quantity of
test material that is taken into the body; quantity of material to be
adminis tered .
DRIFT: The movement of airborne herbicide particles by air motion or wind away
from an intended target area.
ENDANGERED SPECIES: Plant or animal species that are in danger of extinction
throughout all or a significant part of their range. See THREATENED SPECIES.
ENVIRONMENTAL IMPACTS STATEMENT (EIS): An analytical document developed for
use by decisionmakers to weigh the environmental consequences of a potential
action.
EXPOSURE: Application of test material to the external surfaces of a test
organisms; takes into consideration route, duration, and frequency.
-2-
FORAGE: All browse and herbaceous foods available to grazing animals. Forage
may be grazed or harvested for feeding.
FORB: A low-growing herbaceous plant that is not a grass, sedge, or rush.
FORMULATION; (1) A pesticide preparation supplied by a manufacturer for
practical use. (2) A manufacturing process by which technical active
ingredients are prepared for practical use by mixing with liquid or dry
diluents, grinding, or by the addition of emulsifiers, stabilizers, and other
adjuvants.
GROUND COVER: Grasses or other plants that keep soil from being blown away or
washed away.
HABITAT; The environment in which an organism occurs.
HERBACEOUS: Having little or no woody tissues and usually persisting for a
single season.
HERBICIDE: A substance used to inhibit or destroy plant growth. If its
effectiveness is restricted to a specific plant or type of plant, it is called
a selective herbicide. If it is effective for a broad range of plants, it is
called nonselective.
INTEGRATED PEST MANAGEMENT ( IPM) : A systems approach that uses a combination
of techniques (cultural, biological, chemical and regulatory) to achieve
economical pest control in an environmentally sound manner. Cultural methods
include manual, mechanical, prescribed fire, and grazing.
LC : The median lethal herbicide concentration rate of a toxicant at which
50 percent of test animals will be killed. It is usually used in testing of
fish or other aquatic animals, and is usually expressed in parts per million
( ppm) .
LD ; The median lethal dose; the size of a single dose of a chemical
necessary to kill 50 percent of the organisms in a specific test situation. It
is usually expressed in the weight of the chemical per unit of body weight
(mg/kg). It may be fed (oral ^D^^) , or administered in the form of vapors
(inhalation LD^^) .
LEACHING: The movement of chemicals through soil by water or the movement of
herbicides out of leaves, stems, or roots into the air or soil.
METABOLISM: The chemical processes in living cells by which new material is
assimilated and energy is provided for vital processes.
MUTAGEN: A substance that tends to increase the frequency or extent of genetic
mutations (changes in hereditary material).
NO OBSERVED EFFECT LEVEL (NOEL): It is the highest level of chemical dosage at
which no effect is observed; that is, the safe dosage n the species tested.
NONTARGET VEGETATION: Vegetation which is not expected or not planned to be
affected by the treatment.
-3-
NOXIOUS WEED; According to the Federal Noxious Weed Act (PL 93-629) , a weed
that causes disease or has other adverse effects on man or his environment and
therefore is detrimental to the agriculture and commerce of the United States
and to the public health.
ONCOGENIC ( TUMORIGENIC) : Capable of producing or inducing tumors in animals.
The tumors may be either malignant (cancerous) or benign ( non-cancerous) .
ORGANOGENESIS: The time period during embryonic development during which all
major organs and organ systems are formed. During this period, the embryo is
most susceptible to factors interfering with development.
PATHOGEN: A specific causative agent of disease, such as a bacterium or virus.
PELLETED FORMULATION: A dry formulation of herbicide and other components in
discrete particles, usually larger than 10 cubic millimeters.
PERENNIAL PLANT: A plant that completes its life cycle in more than 2 years.
PERSISTENCE: The resistance of a herbicide to metabolism and environmental
degradation and thus a herbicide^s retention of its ability to kill plants for
prolonged periods.
PESTICIDE: Any substance or mixture of substances intended for controlling
insects, rodents, fungi, weeds, and other forms of plants or animal life that
are considered to be pests.
PHOTODEGRADATION: A process of breaking down a substance through reaction to
light.
PHYTOTOXIC: Injurious or lethal to plants.
RARE SPECIES (PLANTS): Plant species not officially listed as threatened or
endangered but that are undergoing a status review or are proposed for listing
by either Federal Register notices published by the Secretary of the Interior
or the Secretary of Commerce or by comparable state documents.
RATE: The amount of active ingredient or acid equivalent applied per unit area
or other treatment unit.
RESEARCH NATURAL AREA: A physical or biological unit in which current natural
conditions are maintained insofar as possible. In such areas, activities such
as grazing and vegetation manipulation are prohibited unless they replace
natural processes and contribute to the protection and preservation of an
area. Such recreation activities as camping and gathering plants are
discourage .
RESIDUE: That quantity of herbicide, its degradation products, and/or its
metabolites remaining on or in the soil, plant parts, animal tissues, whole
organisms, and surfaces.
RESIDUAL HERBICIDE: A herbicide that persists in the soil and injures or kills
germinating weed seedlings, over a relatively short period of time.
-4-
RHIZOME: An underground root-like stem, that produces roots and leafy shoots
and provides a means for some plants to reproduce.
RIPARIAN; Pertaining to or located along a streambank or other water bodies,
such as ponds, lakes, reservoirs, or marshes.
RISK: The probability that a substance will produce harm under specified
conditions.
SAFETY; The reciprocal of risk, i.e., the probability that harm will not occur
under specified conditions.
SCOPING: The process by which significant issues relating to a proposal are
identified for environmental analysis. Scoping includes eliciting public
comment on the proposal, evaluating concerns, and developing alternatives for
consideration.
SEDIMENTATION: The process or action of depositing sediment.
SELECTIVE PESTICIDE: A chemical that is more toxic to some species than to
others .
SPOT TREATMENT; A herbicide applied over a small continuous restricted area of
a whole unit; i.e., treatment of spots or patches of brush within a larger
field .
TERATOGEN: A substance tending to cause development malformations, or
structural abnormalities, of prenatal origin, present at birth or manifested
shortly afterwards; the ability to produce birth defects.
THREATENED SPECIES: Plant or animal species that are not in danger of
extinction but are likely to become so within the foreseeable future throughout
all or a significant portion of their range. See ENDANGERED SPECIES.
TOLERANCE: Acceptable level of pesticide residues. (1) Capacity to withstand
pesticide treatment without averse effects on normal growth and function
(2) the maximum residue concentration legally allowed for a specific pesticide,
its metabolites, or breakdown products, in or on a particular raw agricultural
product, processed food, or feed item. Expressed as parts per million (ppm).
TOXICITY: (1) The capacity or property of a substance to cause any adverse
effects. It is based on scientifically verifiable data from animal or human
exposure tests. (2) That specific quantity of a substance which may be
expected, under specific conditions, to do damage to a specific living
oprganism.
TRANSLOCATION; Movement of a pesticide or other substance within a plant via
the phloem or xylem.
WEED CONTROL: The process of limiting weed infestations or killing weeds for
aesthetic, economic, public health, or other reasons.
-5-
WEED ERADICATION; The elimination of all live parts of plants and viable seeds
of a weed from a site.
WEED SUPPRESSION: The process of retarding weed growth.
WEED: A plant out of place or growing where not desired.
WEED-INFESTED ACRE: An acre of land any part of which that is infested with
weeds .
WILDERNESS: An area designated by Congress as part of the National Wilderness
Preservation System. Wilderness areas are generally undeveloped Federal lands
that retain their primeval character and influence without improvements or
human habitation.
-6-
APgEffl)-iy-2A
BIOLOGICAL EVALUATION FOR THE NOXIOUS WEED PLAN
GALLATIN NATIONAL FOREST
INTRODUCTION
This evaluation is being done for the noxious weed plan for the Gallatin
Naitonal Forest. The selected alternative, integrated pest management,
involves chemical control as the primary method. Other methods include
mechanical and biocontrol agents. With chemical control, toxic substances will
be used, and thus their potential impact on Threatened and Endangered wildlife
and plant species need to be evaluated.
The toxic substances to be used for chemical control of noxious weeds include
picloram and 2-4-D. Both have an identified toxic affect on invertebrates,
fish, birds and mammals ( USDA Technical Report # 633, 1984). Toxicity depends
on dosage, exposure length, and environmental conditions at the time of
exposure.
THREATENED AND ENDANGERED PLANTS AND WILDLIFE AND IDENTIFIED HABITAT
The Gallatin National Forest has no threatened or endangered plants. It does
have the threated grizzly bear and the endangered bald eagle. The endagered
peregine falcon is currently being reestablished on the forest, and we expect
to have resident nesting birds within the next several years.
The Gallatin National Forest has 754,288 acres of grizzly bear recovery
habitat, which includes management situation areas 1 and 2. The location of
important gizzly bear area for females rearing their young are fairly well
identified. These areas generally occur close to and adjacent to Yellowstone
National Park. Density of grizzly bears declines as distance from the Park
increases. However, sporadic appearances of grizzly bears, especially younger
wandering males, can be expected to occur almost any where on the forest.
The location of the bald eagle and peregrine falcon occupied/hacking habitat on
the forest is localized at present to 2 areas. Several bald eagle pairs nest
on Hebgen Lake. And the 2 peregrine falcon hacking sites are located in
Gallatin Canyon. These sites are monitored to determine if and when adult
peregrines will reoccupy the sites and nest there. Any new nesting sites for
both species will be targeted for special management, just as existing sites
are now.
PROJECT IMPACTS
For the bald eagle and peregrine falcon, the known location of existing
occupied habitat makes coordination with weed control relatively easy. It is
-1-
largely a matter of keeping chemical control from contaminating the food supply
for either species within potential or known hunting areas. Both species will
do most of their hunting within 1-2 miles of the nest site. A 2 mile radius
around each known nest site would serve as an adequate buffer for excluding
chemical control. If chemical control of weeds was felt to be the only
feasible means of controling weeds within this habitat radius, further
planning, consultation, and review with the U.S. Fish and Wildlife Service
would be necessary. Chemical contamination of prey species, such as fish,
mammals and birds, would impact any predatory species. Contaminated prey may
have an increased vulnerability and attractiveness to predators, due to
behavior abnormalities and physical disabilities caused from ingesting
pesticides .
The grizzly bear has a low probability of being impacted by the weed control
program. This is due to the small amount of area that will be treated within
grizzly bear habitat (65 acres) as well as the wide ranging nature of the
bear. It is unlikely that they will encounter the treatment areas within the
first severeal weeks of treatment, when chemicals are most toxic. The target
plant species for control, which include leafy sprurge, spotted knapweed,
Canada thistle, musk thistle, whitetop, dalmation toadflax and yellow toadflax
are not preferred grizzly bear foods. And the majority of the treatment areas
include roadsisdes, which bears generally avoid. Bears also usually avoid
trailheads, another potential treatment site, due to the human activity. And
finally, the bears large size requires that they consume a large amount of the
chemical. This is unlikely given that normal control procedures are followed.
The normal means of grizzly bear consuption would likely be through the
consumption of contaminated berries, plants, small mammals, or fish. The
latter pathway probably represents the most likely hazzard, where an accidental
fish kill resulted from chemical contamination of a stream. Prefect design
should prevent such an incident. However, the potential needs to be recognized
and guarded against.
CONCLUSIONS
As a result of this analysis as well as an informal consultation with Dale
Harmes of the U.S. Fish and Wildlife Service on 5/13/86, I believe that the
proposed noxious week program will have no effect on threatened or endangered
wildlife species on the Gallatin National Forest. This is provided that
adequate precautions are taken to prevent unnecessary and excessive
contamination of the localized treatment areas in management situation 1 and 2
grizzly bear habitat, so that contaminated prey species are not made available
to the bear, particular ily fish, and that further project analysis and review
is completed if projects are planned at future dates within a 2 mile radius of
bald eagle nesting habitat, and peregrine falcon nesting and hacking sites.
Sara Jane Johnson
Zone District Biologist
Gallatin National Forest
LITERATURE CITED
USDA. 1984. Pesticide background statements. Volume I. Herbicides.
Agriculture Handbook 633.
-2-
APPENDIX 2B
United States
Department of
Agriculture
Forest Gallatin NF
Service
REPLY TO:
SUBJECT:
TO:
2150 Date: May 1, 1986
Fishery Input into the Gallatin's Weed Control EIS
Forest Supervisor, GNF
This is the fishery input to the Gallatin NF's EIS being written for
chemical weed control. Primary herbicides that the forest proposes to use
are Tordon and 2,4-D. Impacts to fisheries involving application of
chemicals in and around water depend upon toxicity of the chemical on the
concerned fish species, duration or persistence of the chemical, ability of
the chemical to reach live water in a toxic state and means of chemical
application.
1. Tordon: Tordon is the label name for picloram and is considered
highly mobile and persistent in soil. It can remain active in the
soil as long as three years following initial application.
The lethal dose for fish varies among studies and depends upon the
chemical form of herbicide used. The 96 hour LC50 (level of chemical
concentration in the water that is needed to kill 50% of the fish in
a 96 hour period) for cutthroat trout is 1.5 ppm for potassium salt
and 4.8 ppm for trichloropicolinic acid (90-100% pure). Reports in
the EIS developed by the Gallatin NF refers to a LC50 of 50-58 ppm
for Tordon for an unspecified length of exposure time.
2. 2,4-D: The dimethyl amine salt form of 2,4-D is low in both soil
mobility and persistence. The 96 hour LC50 is 100 ppm for rainbow
trout. Another study shows a 96 TLM (median tolerance limit which is
the concentration of toxicant that will allow 50% of the trout to
survive 96 hours) of 1 mg/1 for esters and 900 mg/l for alkanolamine.
Of the two chemicals, Tordon (picloram) is the most toxic, has the
most mobility in soils and is the most persistent.
Recommendations :
It is federal law that both chemicals must be used in strict compliance
with the instructions on the label. It is of particular importance that
Tordon be used in a manner where it will not contaminate water that could
be used for drinking or other domestic uses. Coverage must be limited to
no greater than 25% of the acreage found in any one drainage. It must not
be used where a sandy, porous surface and substrate overlies ground water
closer than 10 feet below the surface. Use should be limited to spot
treatment when working slopes of significant gradient. It must not be
applied within one half mile of where stream or pond water, which drains
from the treated watershed, may be drawn to irrigate suseptible broadleaf
plants .
-1-
A major fishery concern involving the use of herbicides on the Forest
involve small, rearing streams that have little potential for dilution.
The toxic effects of Tordon and 2,4-D have a more of an apparent influence
on young, developing fish at low chemical concentrations then they have on
adult fish. Therefore, it is imperative that proper precautions are used
during application to prevent chemicals from entering important spawning
and rearing aquatic systems.
The Montana Fish, Wildlife and Parks recommend using Tordon in only those
areas that are away from streams and standing water. The chemical 2,4-D
should be carefully applied to these critical areas instead.
It is recommended that the management constraints outlined in the
Gallatin's EIS be adopted in the Gallatin's EIS. Constraints emphasizing
the protection of water resources include:
1. No herbicides will be applied directly to any standing or running
water or where surface water from treated areas can run off into live
water sources.
2. Tordon will not be sprayed within 100 feet of a stream, pond or water
source, within the normal high water level of a stream or
pond -whichever is greater. It will not be sprayed or allowed to
drift into the inner banks of ditches or water channels that carry
water.
It is important that Tordon be applied so that residues in streams and
lakes do not exceed 290 microgram/ liter in the first major rainfall after
application.
/s/James R. Lloyd
JAMES R. LLOYD
Zone Fisheries Biologist
-2-
APPENDIX 3
Proposed Mechanical Treatnent by Districts
Alternative #2
Big Tinber Farn^er District (D-1)
PBOJBCT NAME
TARGET VJEED
NET
SI2E
ACRE
ACRE BY METHCD
■niJ. MOW GHJB
COST
$ M
PROJECT
TYPE 1/
Iron Mtn Eoad
Spotted Knapweed
10.0
10.0
1.54
ROW
Froze to Death Cr
Spotted Knapweed
0.25
0.25
0.039
(»
Graham Creek
Spotted Knapweed
0.10
0.10
0.015
OR
M. Boulder Admin. Past.
Leafy Spurge
0.01
0.01
n/a
OR
Contact Cattle Allot
Leafy Spurge
5.0
5.0
.770
OR
M. Bridger Road
Spotted Knapweed
3.0
3.0
.462
ROW
Deer Cr Cattle Allot
Leafy Spurge
39.0
39.0
6.006
OR/RIP
Sii) total
57.36
8.832
-1-
Livingston Ranger District (D-2)
PROJECT NAME
TARGET WEED
NETT
SIZE
ACRE
ACRE BY METHCD
TILL MCW GRUB
COST
$ M
PROJECT
TYPE
Cottonwood Road
Spotted Knapweed
5.0
5.0
.770
RCW/RIP
Shields River Road ^stem
Canada Thistle
Hounds tongue
10.0
10.0
1.54
ROW/RIP
West Pine Credc Road & ECR
Canada Thistle
Spotted Knapweed
Houndstongue
Hjsk this tie
2.5
2.5
.385
ROW/RIP
Suce Credc Road & ECK
Spotted Knapweed
Houndstongue
Canada Thistle
2.5
2.5
.385
ROW/RIP
Deep Creek Road
and Horse Pasture
Canada Thistle
Houndstongue
1.4
1.4
.216
ROW
Main Mill Creek
Spotted Knapweed
Canada Thistle
Houndstongue
13.25
13.25
2.041
RDW/RIP
Gold Prize Road
and Mine Site
Spotted Knapweed
1.0
1.0
.154
ROW/RIP
West Fork Mill Cr & E(»
Spotted Knapweed
Canada Thistle
Houndstongue
2.0
2.0
.308
RDW/RIP
Emigrant Gulch/
Chico Horse Pasture
Spotted Knapweed
Houndstongue
2.5
2.5
.385
RCW/RIP
Big Credc Station
and A:cess Road
Spotted Knapweed
Houndstongue
2.0
2.0
.308
ROW/RIP/OCC
Smith Creek
Spotted Knapweed
Houndstongue
Canada Thistle
20.5
20.5
3.157
RDW/RIP
Rock Cre^-North
Leafy Spurge
0.25
0.25
0.039
OR
Strickland Creek
Spotted Knapweed
Houndstongue
Canada Thistle
0.25
0.25
0.039
OR
Subtotal 63.15 9.727
-2-
Gardiner Ranger District (D-3)
NET
project nwe
TAHraiT WEED
SIZE
ACRE
ACRE BY METHCD
TILL MOW GFUB
COST
$ M
PROTECT
. .type
Divide Cr Tinber Sale
Spotted Knapweed
Canada Thistle
Hound stongue
1.0
1.0
.154
OR
Divide Cr Eoad
Spotted Knapweed
Canada Thistle
Hound stongue
6.0
6.0
.924
ROW/RIP
Tom Miner-Sunlight Road
Spotted Knapweed
Canada Thistle
Hound stongue
6.0
6.0
.924
ROW/RIP
Eagle Credc Road
Spotted Knapweed
Canada Thistle
Hounds tongue
Toadflax
5.0
5.0
.770
ROW/RIP
Jardine Area Road System
Spotted Knapweed
Canada Thistle
Hounds tongue
14.0
14.0
2.156
ROW/RIP
LaDiite Springs Trailhead
Spotted Knapweed
1.0
1.0
.154
ROW
Joe Brcwn Trailhead
Spotted Knapweed
1.0
1.0
.154
ROW
Blanding Admin Pasture
Spotted Knapweed
1.0
1.0
.154
(»/RIP
Rex Coulee
Spotted Knapweed
0.5
0.5
.770
CR
Cinnibar RR Right-of-VIay
Spotted Knapweed
0.25
0.25
.039
ROW
Yarkee Jim Admin Pasture
Spotted Knapweed
0.50
0.50
.077
ROW
Palmer Mtn Coop
Tinber Sale
Spotted Knapweed
14.0
14.0
2.156
OR
Sd> total
50.25
8.432
-3-
Bozeman Ranger District (D-6)
NET
SIZE ACHE BY METHCD COST PROJECT
PBCOECT NAME ..
TARGET WEED
ACRE TILL MCM
GRUB
$ M
TYPE
Moser Jumxiff
Tinber Sale & Road
Spotted Knapweed
Houndstongue
Canada Thistle
4.2
4.2
.647
RDW/RIP
Beaver Cr Tinber Sale
Spotted Knapweed
Houndstopgue
Canada Thistle
4.0
4.0
.616
ROW/RIP
Bear Credc Tinber Sale
Spotted Knapweed
Houndstongue
Canada Thistle
5.1
5.1
.786
ROW/RIP
Miles Grassy Tinber Sale
Spotted Knapweed
Houndstongue
Canada Thistle
3.1
3.1
.478
ROW
Pine Slushnan Tinber Sale
Spotted Knapweed
Houndstongue
Canada Thistle
3.1
3.1
.478
RGW/RIP
Stone Credc Tinber Sale
and Road
Spotted Knapweed
Houndstongue
Canada Thistle
4.2
4.2
.647
RDW/RIP
Bozeman Cr Tinber Sale
Spotted Knapweed
Houndstongue
Canada Thistle
4.0
4.0
.616
RDW/RIP
Middle Cr Tinber Sale
Spotted Knapweed
4.0
4.0
.616
RDW/RIP
"M' Site
Leafy Spxirge
24.0
24.0
3.696
(»/0CC
Battleridge Aimin. Site
Houndstongue
Canada Thistle
11.0
11.0
1.694
OCC
Squaw Cr - King
Admin. Sites
Houndstongue
Canada Thistle
5.0
5.0
.770
CR
Flathead Pass Road
Spotted Knapweed
Houndstongue
Canada Thistle
2.0
2.0
.308
ROW
Brackett Cr Road Junction
Spotted Knapweed
Houndstongue
Canada Thistle
2.0
2.0
.308
RDW/RIP
Ifyalite Road
Spotted Knapweed
5.0
5.0
.770
RDW/RIP
-4-
Canada Ihistle
Ifyalite-Buckskin Road
Spotted Knapweed
Canada Thistle
5.0
5.0
.770
ROW/RIP
Spanish Cr Almin Site
Spotted Knajweed
2.0
2.0
.308
OCC/RIP
Cascade Cr Trailhead;
Spotted Knapweed
1.0
1.0
.154
ROW
Gredc Cr Canpground
Spotted Knapweed
0.50
0.50
.077
OCC
Swann Cr Campground
Spotted Knapweed
0.50
0.50
.077
OCC/RIP
Subtotal
89.7
13.816
-5-
Hebgen Lake Ranger District (D-7)
TARGET WEED
NET
SIZE
ACRE
ACRE BY METHCD
TILL MOW GEDB
COST
$ M
PROJECT
TYPE
Visitor Center
Spotted Knapweed
7.0
7.0
1.078
OOC
Horse Butte
Canada Thistle
4.0
4.0
.616
ROW
Race Oval
Spotted Knapweed
3.0
3.0
.462
ROW
Subtotal
14.0
2.156
TOTALCAll Districts)
274.46
42. %3
Costs for handgrubbrng maxious weeds were based on costs developed at the Kirgs Hill Hanger
District, Gallatin National Forest for similar projects.
1/ Sites are classified by location types. RCW indicates that treatment occurs near a road
right-of-way. RIP indicates treatment occurs near a piparian habitat (streams, lakes, etc.).
OR indicates that treatment occurs on genneral open raiige or forest lands. OOC indicates that
treatment occurs on a potentially occupied site such as a campground or administrative site.
-6-
APPENDIX 4
Proposed Ground Application of Herbicides by District
Alternative #3
Big Tiirfaer Ranger District (IH)
Project. NamP
Target Weed
Net
Size
Acre
Herbicide Amount Pounds
of Active Ingredient
2,4-D Picloram
Cost
M $
Project 1/
Type
Iron Mtn Road
Spotted Knaiweed
10.0
20.0 lbs
2.5 lbs
.749
ROW
Froze to Death Cr
Spotted Knapweed
0.25
0.0625 lbs
.019
CR
Graham Credc
Spotted Knapweed
0.10
0.025 lbs
.007
OR
M. Boulder Almin Pasture
Leafy Spurge
0.01
0.015 lbs
n/a
OR
Contact Cattle Allot
Leafy Spurge
5.0
7.5 lbs
.375
OR
Main Bridger Road
Spotted Knapweed
3.0
6.0 lbs
0.75 lbs
.225
RCW
Deer Cr. Cattle Allot.
Leafy Spurge
12.0
2.0 lbs
18.0 lbs
.899
CR/RIP
Deer Cr. Cattle Allot.
Leafy Spurge
15.0
4.0 lbs
22.5 lbs
1.124
OR/RIP
Deer Cr. Cattle Allot.
Leafy Spurge
12.0
2.0 lbs
18.0 lbs
.899
OR/RIP
Subtotal
57.36
34.0 lbs
69.3525 lbs
4.297
-1-
Livingston Ranger District (D-2)
Project Name
Target Weed
Net
Size
Acre .
Herbicide Amount Pounds
of Active Ingredient
2.4-D Picloram
Cost
M $.
Project
Type
CbttonMood Road
Spotted Knaiweed
5.0
10.0 lbs
1.25 lbs
.214
RDW/RIP
Shields River Road System
Canada Thistle
Hounds tongue
10.0
20.0 lbs
.427
ROW/RIP
West Pine Credc
Itoad and ECR
Canada Thistle
Spotted Knapweed
Hounds tongue
Hisk thistle
2.5
5.0 lbs
0.625 lbs
.107
RCW/RIP
Suce Cre^ Road
and E(£
Spotted Knapweed
Houndstongue
Canada Thistle
2.5
5.0 lbs
0.625 lbs
.107
RCW/RIP
Deep Credc Road
and Horse Pasture
Canada Thistle
Houndstongue
1.4
2.8
.060
ROW
Main Mill Creek
Spotted Knapweed
Canada Thistle
Houndstongue
13.25
26.50 lbs
3.31 lbs
.566
ROW/RIP
Gold Prize Road
and Mine Site
Spotted Knapweed
1.0
0.25 lbs
.043
RDW/RIP
West Fork Mill
Credc and ECR
Spotted Knapweed
Canada Thistle
Houndstongue
2.0
0.50 lbs
.085
RDW/RIP
Qnigrant Gulch/
Chico HOrse Pasture
Spotted Knapweed
Houndstongue
2.5
5.0 lbs
0.625 lbs
.107
RDW/RIP
Big Creek Station
and Access Road
Spotted Knapweed
Houndstongue
2.0
4.0 lbs
0.50 lbs
.085
RDW/RIP/OCC
Smith Creek
Spotted Knapweed
Houndstongue
Canada Thistle
20.5
41.0 lbs
5.12 lbs
.875
RDW/RIP
Rock Cre^ - North
leafy Spurge
0.25
0.50 lbs
0.625 lbs
.011
CR
Strickland Creek
Spotted Knapweed
Houndstongue
Canada Thistle
0.25
0.50 lbs
0.625 lbs
.011
CR
Subtotal
63.15
120.3 lbs
14.055 lbs
2.698
-2-
Gardiner Banger District (D-3)
. -Xarset. Weed.
Spotted Knapweed
Canada Thistle
Houndstongue
Net
Size
Acjre. -
Herbicide Amount Pounds
of Active Ingredient
2,4-D Picloran
Cost
M $
Project
Divide Cr Tinber Sale
1.0
2.0 lbs
0.50 lbs
.062
OR
Divide Credc Road
Spotted Knaiweed
Canada Thistle
Hound stoiigue
6.0
12.0 lbs
3.0 lbs
.370
ROW/RIP
Tom Miner -
Sunlight Road
Spotted Knapweed
Canada Thistle
Houndstongue
6.0
12.0 lbs
3.0 lbs
.370
ROW/RIP
Ealge Creek Road
Spotted Knapweed
Canada Thistle
Houndstongue
5.0
10.0 lbs
2.5 lbs
.308
ROW/RIP
Jardine Area Road System
Spotted Knapweed
Canada Thistle
Houndstongue
14.0
28.0 lbs
7.0 lbs
.864
ROW/RIP
LaDuke Springs Trailhead
Spotted Knapweed
1.0
2.0 lbs
0.50 lbs
.062
ROW
Joe Brcwn Trailhead
Spotted Knapweed
1.0
2.0 lbs
0.50 lbs
.062
ROW
Blandiig Admin Pasture
Spotted Knapweed
1.0
0.50 lbs
.062
CB/RIP
Rex Coulee
Spotted Knapweed
0.5
0.25 lbs
.031
Cinnabar RR Right-of-Way
Spotted Knapweed
0.25
0.125 lbs
.015
ROW
Yankee Jim Admin Pasture
Spotted Knapweed
0.50
1.0 lbs
0.25 lbs
.031
ROW
Palmer Mtn Co-op
Tiiiber Sale
Spotted Knapweed
Canada Thistle
14.0
28.0 lbs
7.0 lbs
.864
CR
Subtotal
50.25
97.0 lbs
25.125 lbs
3.101
-3-
Bozptnan Ranger District (D-6)
Net Herbicide Anount Pounds
Size of Active Irigredient Cost Project
Project Name
Target Weed
Acre
2.4-D
Picloram
M $
TSqje
Moser Juitpoff
Tiaber Sale & Boad
Spotted Knapweed
Houndstongue
Canada Thistle
4.2
8.4 lbs
2.1 lbs
.351
RGW/RIP
Beaver Credk Tinber Sale
Spotted Knapweed
Houndstongue
Canada Thistle
4.0
8.0 lbs
2.0 lbs
.334
RCW/RIP
Bear Credc Tinber Sale
Spotted Knapweed
Houndstongue
Canada Thistle
5.1
10.2 lbs
2.55 lbs
.426
ROW/RIP
Miles Grassy Tinber Sale
Spotted Knapweed
Hound stoiigue
Canada Thistle
3.1
6.2 lbs
1.55 lbs
.259
ROW
Pine Slushnan
Tinber Sale
Spotted Knapweed
Houndstongue
Canada Thistle
3.1
6.2 lbs
1.55 lbs
.259
RDW/RIP
Stone Credc
Tinber Sale & Road
Spotted Knapweed
Houndstongue
Canada Thistle
4.2
8.4 lbs
2.1 lbs
.351
RDW/RIP
Bozeman Cr Tinber Sale
Spotted Knapweed
Houndstongue
Canada Thistle
4.0
8.0 lbs
2.0 lbs
.334
ROW/RIP
Middle Cr Tinber Sale
Spotted Knapweed
4.0
8.0 lbs
2.0 lbs
.334
RCW/RIP
"M' Site
Leafy Spurge
24.0
24. lbs
2.006
OR/OCC
Battleridge Admin Site
Houndstongue
Canada Thistle
11.0
22.0 lbs
.920
OCC
Squaw Cr - King
Admin. Sites
Houndstongue
Canada Thistle
5.0
10.0 lbs
.418
CR
Flathead Pass Road
Spotted Knapweed
Houndstongue
Ckeye Daisy
2.0
4.0 lbs
1.0 lb
.167
ROW
Brackett Cr. Road Junction
Spotted Knapweed
2.0
4.0 lbs
1.0 lb
.167
ROW/RIP
Houndstongue
Canada Thistle
-4-
Ifyalite Koad
Spotted Knapweed
Canada Uiistle
5.0
10.0 lbs
2.5 lbs
.418
ROW/RIP
Ifyalite-^uckdcin Koad
Spotted Knapweed
Canada Thistle
5.0
10.0 lbs
2.5 lbs
.418
OOC/RIP
Spanish Credc Almin Site
Spotted Knapweed
2.0
4.0 lbs
1.0 lbs
.167
ROW
Cascade Cr Trailhead
Spotted Knapjeed
1.0
2.0 lbs
0.50 lbs
.084
OOC
Greek Credc Caaopground
Spotted Knapweed
0.50
1.0 lbs
0.25 lbs
.042
OCC
Swam Creek Canpground
Spotted Knapweed
0.50
1.0 lbs
0.25 lbs
.042
OOC/RIP
Sii> total
89.7
131.4 lbs
48.85 lbs
>.497
-5-
Hebgen Lake Ranger District (D-7)
Project Name
Target Weed
Net
Size
Acre
Herbicide Amount Pounds
of Active Ingredient Cost
2.4-D Picloram M $
Project
Type
Visitor Center
Spotted Knapweed
7.0
4.9 lbs
.350
OCC
Horse Butte
Canada Thistle
4.0
2.8 lbs
.200
RCW
Race Oval
Spotted Knapweed
3.0
2.1 lbs
.150
ROW
Subtotal
14.0
0.0
9.8 lbs
0.7
TCOAL
274.45
382.7
167.1825
18.293
Ihe above costs were determined from averages each District felt were representative for
their area. Travel time, access to the site, etc. were considered in when determining
these costs.
1/ Sites are classified by location types. ROW indicates that treatment occurs near a
road right-of-way. RIP indicates treatment occures near a riparian hdDitat (streams,
lakes, etc.). CR indicates that treatment occurs on general open range or forest lands.
CXX indicates that treatment occurs on a potentially occupied site such as a canfjground or
administrative site.
-6-
APPEMJK 5
Proposed Integrated Treatment by District
Big Tinfaer Rangpr District (D-1)
Proiect Name
Target Weed
Net
Size
Acre
Acre
Gnl)
Heibicide Amount lbs
of Active Ingredient
2.4-D Picloram
Cost
$ M
Project
Tvoe
Iron Mtn Road
Spotted Knapweed
10.0
0
20.0 lbs
2.5 lbs
.75
ROW
Froze to Death Cr
Spotted Knapweed
0.25
.1
0
.0375 lbs
.027
OR.
Grahan Credc
Spotted Knapweed
0.10
.05
0
.0125 lbs
.011
OR
M. Boulder Admin Past
leafy Spurge
0.01
0
0
.015 lbs
.007
OR
Contract Cattle Allot
Leafy Spurge
5.0
0
0
7.5 lbs
.375
CR
M. Bridget Road
Spotted Knapweed
3.0
0
6.0 lbs
0.75 lbs
.225
ROW
Deer Cr Cattle Allot
leafy Spurge
39.0
0
8.0 lbs
58.5 lbs
2.925
Subtotal
57.36
.15
34.0 lbs
69.315 lbs
4.32
-1-
Livingston Ranger Pi
Proiect Name
Target Weed
Net
Size
Acre
Acre
Gnl)
Herbicide Amount lbs
of Active Ingredient
2.4-d Picloram
Cost
$ M
Project
Type
CottoiHMOod Eoad
Spotted Knapweed
5.0
0
10.0 lbs
1.25 lbs
.210
ROW/RIP
Shield River
Road System
Canada Thistle
Houndstongue
10.0
0
20.0 lbs
0
.420
RDW/RIP
West Pine Creek
Road & EOR
Canada Thistle
Spotted Knapweed
Houndstongue
Mask thistle
2.5
0
5.0 lbs
0.625 lbs
.105
BDW/RIP
Slice Cr Road & EOR
Spotted Knapweed
Houndstongue
Canada Thistle
2.5
1.25
2.5 lbs
0.3125 lbs
.245
ROW/RIP
Deep Cr Road
and Horse Pasture
Canada Thistle
Hound stoiigue
1.4
.7
1.4 lbs
0
.137
ROW
Main Mill Credc
Spotted Knapweed
Canada Thistle
Houndstongue
13.25
0
26.5 lbs
3.31 lbs
.557
ROW/RIP
Gold Prize Road
and Mine Site
Spotted Knapweed
1.0
0
0
.25
.042
ROW/RIP
West Fork Mill Cr
and ECH
Spotted Knapweed
Canada Thistle
Houndstongue
2.0
0
0
0.50 lbs
.084
ROW/RIP
Emigrant Gulch
Chico Horse Pasture
Spotted Knapweed
Hound stoiigue
2.5
0
5.0 lbs
0.625 lbs
.105
ROW/RIP
Big Cr Station
and lk:cess Road
Spotted Knapweed
Houndstongue
2.0
0
4.0 lbs
0.50 lbs
.042
ROW/RIP/OCC
Smith Credi
Spotted Knapweed
Houndstongue
Canada Thistle
20.5
0
41.0 lbs
5.12 lbs
.861
ROW/RIP
Rock CreA - North
leafy Spurge
0.25
0
0.5 lbs
0
.011
OR
Strickland Creek
Spotted Knapweed
Houndstongue
Canada Thistle
0.25
0
0.5 lbs
0.625 lbs
.011
CR
Subtotal
63.15
1.95
116.4
18.754
2.83
-2-
Gardiner Ranger District (D-3)
Proiect Name
Target Weed
Net
Size
Acre
Acre
Grvi>
Herbicide Amount lbs
of Active Ingredient
2 .4-d Pic loram
Cost
$ M
Project
Divide Cr Tinber Sale
Spotted Knapweed
Canada Thistle
Hounds tongue
1.0
1.0
0
0
.154
OR
Divide Cr Road
Spotted Knapweed
Canada Thistle
Houndstongue
6.0
0
12.0
3.0 lbs
.372
ROW/RIP
Horn Hiner -
Sunlight Road
Spotted Knapweed
Canada Thistle
Houndstongue
6.0
0
12.0 lbs
3.0 lbs
.372
ROW/RIP
Eagle Cr Road
Spotted Knapweed
Canada Thistle
Houndstongue
Toadflax
5.0
0
10.0 lbs
2.5 lbs
.310
ROW/RIP
Jardine Area
Road System
Spotted Knapweed
Canada Thistle
Houndstongue
14.0
0
28.0 lbs
7.0 lbs
.868
ROW/RIP
LaDuke Springs
Trailhead
Spotted Knapweed
1.0
1.0
0
0
.154
ROW
Joe Brown Trailhead
Spotted Knapweed
1.0
1.0
0
0
.154
ROW
Blandiiig Admin Pasture Spotted KnajMeed
1.0
.5
0
.25
.093
OR/RIP
Rek Coulee
Spotted Knapweed
0.5
.25
0
.125
.055
OR
Cinnabar RR
Right-of-4/^
Spotted Knapweed
0.25
.25
0
0
.039
ROW
Yarkee Jim
Admin. Pasture
Spotted Knapweed
0.50
.25
0.516
.125
.055
ROW
Palmer Mtn Co-op
Tinber Sale
Spotted Knapweed
Canada Thistle
14.0
0
28.0 lbs
7.0 lbs
.868
OR
Subtotal
50.25
4.25
90.5 lbs
23.0 lbs
3.494
-3-
Bozeman Ranger Pi
Pppiept; NgqR
Target Weed
Net
Size
Acre
Acre
Grub
Herbicide Amount lbs
of Active Ingredient
2.4-d Picloram
Cost
$ M
Project
Tgie
Moser Junpoff
Tinber Sale & Boad
Spotted Knapweed
Houndstongue
Canada Thistle
4.2
0
8.4 lbs
2.1 lbs
.353
BOW/RIP
Beaver Cr Tinber Sale
Spotted Knapweed
Houndstongue
Canada Thistle
4.0
0
8.0 lbs
2.0 lbs
.336
BOW/RIP
Bear Cr Tinber Sale
Spotted Knapweed
Houndstongue
Canada Thistle
5.1
0
10.2 lbs
2.55 lbs
.429
BOW/RIP
Miles Grassy
Tinber Sale
Spotted Knapweed
Houndstongue
Canada Thistle
3.1
0
6.2 lbs
1.55 lbs
.260
ROW
Pine Slushnan
Tinber Sale
Spotted Knapweed
Houndstongue
Canada Thistle
3.1
0
6.2 lbs
1.55 lbs
.260
ROW/RIP
Stu>ne Cr Tinber
Sale and Boad
Spotted Knapweed
Houndstongue
Canada Thistle
4.2
0
8.4 lbs
2.1 lbs
.353
RDW/RIP
Bozeman Credc
Tinber Sale
Spotted Knapweed
Houndstongue
Canada Thistle
4.0
2.0
4.0 lbs
1.0 lbs
.476
RDW/RIP
Middle Creek
Tinber Sale
Spotted Knapweed
Houndstongue
Canada Thistle
4.0
0
8.0 lbs
2.0 lbs
.336
RCW/RIP
"M' Site
Leafy Spurge
24.0
0
0
24.0 lbs
2.016
OR/CCC
Battleridge
Admin. Site
Houndstongue
Canada Thistle
11.0
0
22.0 lbs
0
.924
OCC
Squaw Credc
King Admin. Site
Houndstongue
Canada Thistle
5.0
0
10.0 lbs
0
.420
CR
Flathead Pass Boad
Spotted Knapweed
Houndstongue
Ckeye Daisy
2.0
0
4.0 lbs
1.0 lbs
.168
ROW
Brackett Creek
Boad Junction
Spotted Knapweed
Houndstongue
2.0
0
4.0 lbs
1.0 lbs
.168
ROW/RIP
-4-
Canada Thistle
Ifyalite Road
Spotted Knapweed
Canada Thistle
5.0
1.25
7.5 lbs
1.875 lbs
.508
ROW/RIP
Ifyalite-Buckdcin Rd
Spotted Knapweed
Canada Thistle
5.0
1.25
7.5 lbs
1.875 lbs
.508
OOC/RIP
Spanish Credc
Almin. Site
Spotted Knapweed
2.0
1.0
2.0 lbs
.5 lbs
.238
ROW
Cascade Cr Trailhead
Spotted Knapweed
1.0
0
2.0 lbs
0.50 lbs
.084
OOC
Gredc Cr Can^iground
Spotted Knapweed
0.50
.25
0.5 lbs
0.125 lbs
.025
OOC
^an Cr Caifiground
Spotted Knapweed
0.50
.25
0.5 lbs
0.125 lbs
.060
OOC/RIP
Subtotal
89.7
6.
119.4 lbs 45.85 lbs
7.922
-5-
Ild?gen lAe Ranger District (D-7)
Net Herbicide Amount lbs
Size Acre of Active Ii^gredient Cost Project
Proiect N?®ne
Target Weed
Acre
Gri±)
2.4-d
Pic lorfnn
$ M Type
Visitor Center
Spotted Knapweed
7.0
0
0
4.9 lbs
.350 OOC
Horse Butte
Canada Ihistle
4.0
2.0
0
1.4 lbs
.408 ROW
Race Oval
Spotted Knapweed
3.0
0
0
2.1 lbs
.150 ROW
Subtotal
14.0
2.0
0
8.4 lbs
.908
Total
274.46
14.36
360.3
165.319 lbs
19.474
1/ Sites are classifed by location types. ROW indicates that treatment occurs near a road
right-of-way. RIP indicates treatment occurs near a riparian habitat (streams, Idces, etc.). CR
indicates that treatment occurs on general open rarge or forest lands. OOC indicates that treatment
occurs in a potetially occupied site such as a canpground or administrative site.
-6-
APPENDIX 6
Estimated Cost of Noxious Weed Control by Method of Treatment and District
Big Timber Ranger District (D-1)
$50-$75/Acre Spraying Backpack Sprayer
No Mechanical Treatment
No Biological Control
Livingston Ranger District (D-2)
$10-$12/Acre Tordon 2K 1/4 lb
$12-$14/Acre Tordon 22K - 2 ,4-D Mix
$20/Acre Labor - tordon 2K Access
$75/Acre
$30/hr plus chemical - County Costs
$28/hr Fctourous - $50/Mile
$40 - Low End $85/Acre i.e. Travel Time
Pulled Up Small Infestations, Weevils On Thistle
Gardiner Ranger District (D-3)
$55-v60/Acre Spraying
No Mechanical Treatment
No Biological Control
Bozeman Ranger District (D-6)
$80-$100/Acre Pellets
$20-$30/Acre Spray
No Mechanical Control
Biological Control
Seed-head Weevil (Rhinocyclus Conicus) on Muskthistle at Battleridge.
Hawkmoth (Hyles Euphorbice) on Leafy Spurge - "M"
-1-
Hebgen Lake Ranger District (D-7)
$50 /Ac re Spraying
Mechanical Control
Bakers Hold Campground <1 Acre Grubbing Spotted Knapweed
Jump Center <1 Acre Grubbing Spotted Knapweed
Spurge Rate = 12%
Spotted Knapweed - 27%
County - 64.00/Acre heavy
59.50/Acre light
Kings Hill Ranger District Gallatin Jim Armstrong
Grubbing - $154/Acre If lots of rock.
Mowing - $60/Acre Roadside zones.
Patrol Costs $45/Acre
Control Costs $30/Acre
APPENDIX 7 - Available at Gallatin National Forest, Supervisor's Office only.
— Z -
APPENDIX 8A
HUMAN HEALTH RISK ANALYSIS
FOR PROPOSED HERBICIDE SPRAY PROGRAMS TO CONTROL NOXIOUS WEEDS
ON THE GALLATIN NATIONAL FOREST
This appendix analyzes the risk to human health as a result of herbicide spray
programs to control noxious weeds on the Gallatin National Forest. The
integrated pest management alternative includes herbicide applications of 2,4-D
and picloram (Tordon, tradename) onto approximately 260 acres of rangeland,
road right-of-way (ROW), riparian habitat, and potentially occupied sites such
as administrative sites and campgrounds. These 260 acres of spray area are
scattered across approximately 1.7 million acres of the Gallatin National
Forest.
Appendices 3, 4, and 5 classify the projects proposed under each alternative by
location type. In the tables in these appendices the abbreviation ROW
indicates that spraying occurs near a road right-of-way. RIP indicates that
spraying occurs near riparian habitat (streams, lakes, etc.). OR indicates the
spraying occurs on general open range or forest lands. OCC indicates spraying
occurs on a potentially occupied site such as a campground or administrative
site.
Analyses of human health impacts are provided for the worst-case example of
each type of project. These worst-case examples are defined on the basis of
proximity to water and residents, size of the spray area, and the amount of
herbicide sprayed.
Worst-case Open Range/Riparian Project
Exposure Analysis
In terms of amount of herbicide applied, the worst-case open range project is
the Deer Creek project on the Big Timber Ranger District. This project
involves spraying more than 58.5 pounds of picloram active ingredient (a.i.) on
39 net acres and 8 pounds (a.i.) of 2,4-D onto 4 acres to control noxious
weeds. These 43 total acres of noxious weeds are actually isolated
infestations of 10 acres or less spread over approximately 2,500 acres of
ground. The nearest residence is further than 1 mile from an area being
sprayed although the analysis below assumes that a residence is within 200
meters (one-eighth mile) of this project. No spraying occurs on any open range
closer than three-quarter mile to a residence. There are several small creeks
in the area with flow rates ranging from 0.5 to 3.5 cubic feet per second.
The analysis of the Deer Creek project will be based on the analysis of the
potential impacts of a 500-acre project involving the application of 150
pounds of picloram (including mixing and formulation errors) in combination
with 2,4-D. Since very little 2,4-D is being sprayed, 2.4-D impacts are based
on the analysis of a 20-acre project involving the application of 48 pounds of
2,4-D. The development of the 500-acre and 20-acre project analyses is
contained in a document entitled "Analysis of Human Health Risks of the USDA
Forest Service Use of Herbicides to Control Noxious Weeds in Region 1"
(referred to below as the Background Document). This document is included as
Appendix 8B of this Environmental Impact Statement.
-1-
The analysis of the model projects contained in the Background Document assumed
that the spray site is continuous (i.e., not spread over a wide area) thus
maximizing drift to adjacent areas. A residence is assumed to be located
within 200 meters (220 yds) of the border of the nearest spray area. The
residence is assumed to be downwind of the spray site and the residents are
assumed to be outside and exposed to drift during the entire spray period. The
residents are assumed to have a vegetable garden located adjacent to the
house. In addition, the residents are assumed to consume a steer which has
grazed exclusively on herbicide-treated grass and accumulated the maximum body
burden of the herbicide. Residents or visitors are assumed to drink water and
consume fish from a stream containing herbicide runoff.
Based on all critical exposure parameters, the actual Deer Creek project will
provide less exposure to members of the general population than that calculated
for the applicable open-range projects in the Background Document. Less
herbicide would be applied in the Deer Creek project than is assumed in the
large model project analyzed in the Background Document. The herbicide is
applied over a large area thus concentrated drift will not occur. The nearest
residence to the Deer Creek project is further than 1 mile from the spray
area. However, the doses to these residents near the Deer Creek project are
based on the assumption that the residences, gardens, and residents are only
220 yards from the spray site.
In addition to resident dose values, dose values are also provided for visitors
who enter the area after spraying is completed and visitors who enter the spray
area and consume 0.5 pound of vegetation that has been directly sprayed with
picloram or 2,4-D. The Background Document in Appendix 8B provides all
assumptions and calculations used to derive the potential doses to visitors and
residents .
Table 1 provides dose values for members of the general population for the
various exposure pathways of concern. Table 1 is derived in part from the
Background Document's Table 2.17 (2,4-D doses) and Table 2.27 (picloram
doses). In addition, the doses resulting from water contamination are based on
information presented in Section 2. 4. 6. 4 of the Background Document. The doses
presented on Table 1 for fish and water consumption assume that 2 percent of
the 22 pounds of picloram and 4 pounds of 2,4-D sprayed near Corker Canyon (0.5
cfs stream) is washed into the stream in a 24-hour period. The stream is also
assumed to be a productive fishery.
As indicated on Table 1, the highest doses are dietary in origin. All of these
doses are highly improbable. For example, the highly scattered nature of the
spray sites (43 acres in 2,500 acres) insures that herbicide-treated vegetation
will constitute a smaller portion of the diet of cattle than assumed in the
Background Document. In addition, cattle apparently have a taste aversion to
2 ,4-D/pic loram and refuse to graze on leafy spurge, sprayed or otherwise.
Thus, the probable dose to human consumers would be much less than calculated
here and probably nondetectable.
-2-
Table 1. — Worst-case dose levels to visitors and residents in the vicinity of
a large, open-range project sprayed with a 2 ,4-D/picloram mixture.
2,4-D dose
(milligram of
herbicide per
kilogram of body
weight p£X-dayj
Picloram dose
(milligram of
herbicide per
kilogram of body
weight per day)
Adult direct dose from drift 0.00008
Adolescent direct dose from drift 0.00010
Infant direct dose from drift 0.00020
Adult/adolescent oral dose from
consuming beef cattle dosed with
herbicide 0.00071
Infant oral dose from consuming
beef cattle dosed with herbicide 0.00083
Adult/adolescent oral dose from
consuming vegetables from a
garden impacted by drift 0.0031
Infant oral dose from consuming
vegetables from a garden impacted
by drift 0.0038
Adult oral dose (water) 0.0008
Adolescent oral dose (water) 0.0011
Infant oral dose (water) 0.0012
Adult-adolescent oral dose (fish) 0.0002
Infant oral dose (fish) 0.0003
Visitor re-entry to spray site 0.0005
Oral dose from consumption of
sprayed wild food Pf Q56
0.000003
0.000004
0.000007
0.00071
0.00083
0.0012
0.0016
0.0046
0.0061
0.0067
0.0011
0.0017
0.00011
0.007
-3-
The probability of human consumption of sprayed wild vegetation is also very
small. The isolated nature of spray sites, the absence of wild foods in leafy
spurge infestations, and the small percentage of the area being sprayed would
make doses at this level very unlikely. In addition, in concentrations above 5
parts per million (ppm) on food, picloram and 2,4-D impart a very bitter taste
to food thus limiting palatibility.
The oral doses from eating vegetables from a garden impacted with drift are
also overestimates because the garden is assumed to be within 220 yards of a
500-acre spray area. The nearest garden to the Deer Creek project is over 1
mile away and there are no gardens within three-quarters of a mile of any
smaller open-range projects. Thus, probable doses are hundreds to thousands of
times smaller than indicated here.
Health Implications of Doses; Thres held Effects
Having defined the extreme outermost limits of doses that could be anticipated
under any circumstances associated with the open-range spraying of noxious
weeds, the significance of these doses must be determined. At some dose level
all chemicals will have adverse effects. For some health effects of herbicides
such as general toxic effects on kidney or liver function or reproductive
effects on pregnant females, a dose level can be defined below which these
effects would not occur. This level is often defined as the no-observed -effect
level (NOEL).
For ethical reasons, testing of chemicals to define NOEL's is not performed on
humans but rather on animal surrogates. The problem of extrapolating results
from animals to humans has provoked much debate. The procedure adopted by most
regulatory or advisory agencies, such as the U.S. Environmental Protection
Agency (EPA), the Food and Drug Administration (FDA), and the World Health
Organization (WHO), is to divide the NOEL (derived from the test animal that is
most sensitive to the chemical) by a safety factor. The safety factor is
designed to account for possible differences between humans and animals and
also to account for the fact that some humans are more sensitive to chemicals.
The EPA has determined Acceptable Daily Intake (ADI) levels for both 2,4-D and
picloram. The ADI is defined by EPA as the dose that could be taken everyday
for a lifetime without adverse effects. As discussed in Section 2.5 of the
Background Document, the ADI for 2,4-D was defined by EPA by dividing the NOEL
of 1.0 mg/kg/day by a safety factor of 100 (ADI = 0.01 mg/kg/day). The
picloram ADI was defined by dividing the NOEL of 50 mg/kg/day by a safety
factor of 2,000 (ADI = 0.0250 mg/kg/day). A smaller safety factor for 2,4-D
was used because more long-term testing is available with the compound.
The extreme dose estimates for the Deer Creek project can be compared to the
ADI's. This comparison makes the further conservative assumption that a
maximum-exposed resident is directly exposed to drift and than eats from a
contaminated vegetable garden and consumes contaminated beef on the same day.
Table 2 provides ADI comparisons which are developed by dividing the ADI by the
dose. If the dose is less than the ADI, the resulting number will be greater
than one. The larger the number, the greater the "margin of safety".
-4-
As shown on Table 2, with but one exception, all combinations of dose are below
the ADI. The only way a person could get a dose above the ADI for 2,4-D, would
be to visit a spray site and then eat one-half pound of vegetation that has
been directly sprayed. This is highly unlikely since these leafy-spurge
infested range sites do not contain vegetation considered edible by humans.
Table 2. — ADI dose comparison for maximum-exposed residents and visitors in the
vicinity of a large, open-range project sprayed with 2 ,4-D/pic loram.
Adult resident
Adolescent resident
Infant resident
Visitor re-entry
Visitor re-entry with
consumption of sprayed
2.4-D
Pic loram
2.6
13
2.6
13
2.1
10
2.0
23
. Abaye
3.6
Were the assumptions of this "wild-food consumption" scenario met, the dose
would still be about one-half the 2,4-D NOEL as determined in long-term feeding
studies with rats. At dose levels above 1.0 mg/kg/day, minor effects on kidney
function were noted. Since 2,4-D breaks down quickly on vegetation (half
would typically disappear in less than a week) , the chance for long-term
exposure is again minimal.
The highest possible 2,4-D or picloram doses are also more than 1,000 times
lower than the doses that affect fetuses in the most sensitive animal species
tested .
Some potential effects of chemical exposure are not reversible once initiated.
These effects include cancer and mutations that might be passed on from one
generation to another. This analysis assumes that 2,4-D and picloram can cause
cancer and that every additional dose of 2,4-D and picloram increases one s
probability of developing cancer. In other words, this analysis assumes that
from the perspective of cancerous effects, there is no such thing as an
absolutely safe dose of a carcinogen (cancer-causing chemical).
-5-
Section 2.7 of the Background Document discusses the very conservative model
that is used to predict the probability of cancer from various doses. Table 3
provides cancer probabilities for various exposure pathways for the Deer Creek
Project. This table is derived from Tables 2.83 and 2.92 of the Background
Document. As discussed in Section 2.7.8 of the Background Document, these
cancer probabilities assume long-term exposure to 2,4-D and picloram. For
example, the residents were assumed to eat contaminated beef for for 140 days
and contaminated gard'en vegetables for 42 days.
Table 3. — Cancer probabilities for visitors and residents in the vicinity of
a large, open-range project sprayed with a 2 ,4-D/pic loram mixture.
Adult dermal dose
Adolescent dermal dose
Infant dermal dose
Adult/adolescent oral
dose (beef)
Infant oral dose (beef)
Adult/adolescent oral
dose (veg)
Infant oral dose (veg)
Adult oral dose (water)
Adolescent oral dose (water)
Infant oral dose (water)
Adult/adolescent oral dose
fish
Infant oral dose (fish)
Visitor re-entry to spray
site 1 day
Oral dose/sprayed wild
food 1 day
Probability from
2j4rP. dose
3.2
4.3
8.0
2.0
2.3
1.5
1.8
1.6
2.2
2.4
3.9
5.9
1.0
1.1
X
X
X
X
X
X
X
X
X
X
X
X
X
X
10
10
10
10
10
10
10
10
10
10
10
10
10
10
-11
-11
-11
-8
-8
-8
-8
-10
-10
-10
-11
-11
-10
-8
Probability from
2.0 X
2.7 X
4.7 X
2.2 X
2.6 X
6.5 X
8.7 X
1 .0 X
1.4 X
1.5 X
2 . 5 X
3.8 X
2.4 X
1.6 X
10
10
10
10
10
10
10
10
10
10
10
10
10
10
-13
-13
-13
-9
-9
-10
-10
-10
-10
-10
-11
-11
-12
-10
-6-
For maximum-exposed residents, the cancer probabilities from various exposure
pathways can be added together. For example, the cancer probability for an
infant exposed to^drift, contaminated beef and garden vegetables would be 4.455
X 1^ (8.0 X lO'J + 2.3 X 10 + 1.8 x 10 + 4.7 x 10 “ + 2.6 x
10 + 8.7 X 10 ). In other words, the infant has about five chances in
100 million of developing cancer from the cumulative impacts of all doses of
2,4-D and picloram. If, for 5 consecutive years, the Forest Service were to
treat this project and an infant were to get allgworst-case doses, his cancer
probability would be 2.2 x 10 (5 x 4.455 x 10 ) or about two chances in
10 million.
The assessed risk of cancer that could occur from using 2,4-D and picloram to
control noxious weeds is only meaningful to the decisionmaker or other readers
if it can be compared to similarly determined risks for known cancer-causing
agents (such as x-rays or smoking) or other risks of death. Some risks are so
small that people tend to ignore them because they are uncgnsciously accepted
(e.g., crossing a street). For example, many risks of 10 per year (one
chance in a million) are familiar and casually accepted by the general public.
Weighted lifetime risks of cancer to an individual exposed to 2,4-D and
picloram can be compared to a number of risks familiar to society as listed in
Table 4 (taken from Table 2.98 of the Background Document). The cancer risks
shown in Table 4 were calculated by a method similar to that used in this
analysis; so the same uncertainties with exposure, measurements of potency, and
extrapolation between laboratory animals and humans apply. In all cases, the
lifetime risk of cancer resulting from exposure to 2,4-D and picloram is lower
than the risk of cancer from smoking two cigarettes, drinking 40 diet_godas, or
having a single x-ray in a lifetime, which ere all in the order of 10 or
one-in-a-million risk. Cancer risk in the use of 2,4-D and picloram is
obviously a major concern; although the project decisionmaker must establish a
frame of reference in evaluating the magnitude of this risk.
Based on data discussed in Section 2.7 of the Background Document, neither
2,4-D or picloram involve significant mutagenic potential. Since mutagenicity
and carcinogenicity both follow similar mechanistic steps (at least those that
involve genetic toxicity), the increased risk of cancer can be used to
approximate the quantitative risk of heritable mutations (birth defects). The
basis for this assumption is that both mutagenicity and at least primary
carcinogens react with DNA to form a mutation, or DNA lesion, affecting a
particular gene or set of genes. The genetic lesions then require specific
metabolic processes to occur or the cells must divide the lesion into the
genetic code of the cell. We believe the cancer risk provides a worst-case
approximation to heritable mutations because cancer involves many types of
cells whereas heritable mutations involve only germinal (reproductive) cells.
Therefore, the worst— case risk of heritable mutations is less than one chance
in 10 million.
-7-
Table 4. — Lifetime risk of death or cancer resulting from everyday activities
(from Crouch and Wilson (1982)).
Activity
'
Time to accumulate
a one-in-a-million
risk of death
Average annual
_risk cer cauita
Living in the United States
-4
Motor vehicle
acc ident
1.5 days
2
X
'°-5
Falls
6 days
6
X
10.5
Drowning
10 days
4
X
10.5
Fires
13 days
3
X
^°-5
F irearms
36 days
1
X
Electrocution
2 months
5
X
10-7
Tornados
20 months
6
X
10-7
Floods
20 months
6
X
10-7
Lightning
2 years
5
X
10-7
Animal bite or
, Sting
4. yeara
a.
_JL.
Occupational Risks
General
manuf ac tur ing
4.5 days
8
X
10
trade
7 days
5
X
10
service & government
3.5 days
1
X
10
transport & public utilities
1 day
4
X
10
agriculture
15 hours
6
X
10
construction
14 hours
6
X
10
mining and quarrying
Spec if ic
9 hours
1
X
10
coal mining (accidents)
14 hours
6
X
10
police duty
1.5 days
2
X
10
railroad employment
1 . 5 days
2
X
10
fire fighting
11 hours
8
X
10
Source of risk
One-In-A-Mil lion Risks of Cancer
Cosmic rays One transcontinental round trip by air; living 1.5 months in
Colorado compared to New York; camping at 15,000 feet over 6
days compared to sea level.
Other 20 days of sea level natural background radiation; 2.5
months in masonry rather than wood building; 1/7 of a chest
x-ray using modern equipment.
Eating & drinking 40 diet sodas (saccharin)
6 pounds of peanut butter (aflatoxin)
180 pints of milk (aflatoxin)
200 gallons of drinking water from Miami or New Orleans
90 pounds of broiled steak (cancer risk only)
Smok ing
2_gjgaj£^.t£S
-8-
Impacts. on, j/orlS£rs. from Open-Range Spraying
Herbicide application on a project the size of Deer Creek will require four
workers about 10 days each to complete using backpack sprayers and
truck-mounted tanks with hand sprayer attachments. Each applicator would
either apply about 2.0 pounds (0.9 kilograms) of 2,4-D or 1.5 pounds (0.7
kilograms) of picloram per day.
Worker-dose data is not available for conditions typifying the spraying of
noxious weeds. The Background Document extrapolates from data on workers
spraying brushfields 5 to 15 feet high with backpack sprayers. Because of the
excessive dermal exposure resulting from full body contact with wet vegetation
as well as the spray fallout involved in spraying over one's head, this data
overestimates dose from spraying noxious weeds that are less than 3 feet high.
In addition, these workers in the forestry study wore little protective
clothing, often only short-sleeved or sleveless shirts and no gloves. Dose
estimates for backpack sprayers based on this forestry study would range from
0.09 mg/kg/day to worst-case values of 0.21 mg/kg/day for 2,4-D ((0.9 kg x
0.234 mg/kg/kg/) (see Sections 2.4.1 and 2.6.2 of the Background Document).
As discussed in the Background Document (Section 2.4.1), less data is available
for workers applying picloram with backpack sprayers. As noted in the
Background Document, dermal absorption for 2,4-D is higher than picloram (6
percent versus less than 1 percent). When 2,4-D and picloram are applied
together, the picloram doses are generally one-third to one-tenth the 2,4-D
dose when differences in application amount are allowed for. Assuming as an
extreme that picloram dose rates (weighted for application amount) are the same
as 2,4-D, the worst-case picloram dose would be 0.16 mg/kg/day (0.7 kg x 0.234
mg/kg/day). An assumption that the picloram dose is one-fifth of the 2,4-D
dose (weighted for application amount) , would give a more realistic dose
estimate of 0.03 mg/kg/day (0.16 mg/kg/day x 0.2).
As noted above, calculated doses include the implicit assumption that workers
work with bare hands and wear ordinary work clothing such as cotton pants and
short-sleeved shirts. It is common practice; however, for herbicide
applicators to wear clothing that affords more protection. Typical clothing
often includes long-sleeved shirts and coveralls, gloves and hats.
Research reviewed since the completion of the Background Document has shown
that such protective clothing can reduce worker exposure by 27 to 99 percent.
For example, in right-of-way spraying, doses of spray gun applicators wearing
clean coveralls and gloves were reduced by 68 percent compared to the doses
they got without this protection (Libich et al. 1984).
During insecticide applications to orchards, mixers reduced their exposure by
35 percent and sprayers reduced their exposure by 49 percent by wearing
coveralls (Davies et al. 1982). Putnam and coworkers found that nitrofen
applicators and mixer/loaders wearing protective clothing reduced their
exposure by 94 to 99 percent compared to the doses experienced without
-9-
protection (Waldron 1985). Although protective clothing generally does reduce
worker exposure and resulting doses, the degree of protection depends on the
application system, the work practices, and the specific herbicide. In the
forestry application study used as a basis for backpack sprayer doses, workers
wearing more clothing did not receive significantly lower doses than workers
with less clothing. In this case, backpack applicators had to treat and move
through dense vegetation that was taller than themselves.
Under the less rigorous conditions of noxious weed spraying, additional
protective clothing is assumed to reduce backpack worker dose by 68 percent.
Table 5 summarizes worker doses (backpack and hand-gun sprayers) based on
various assumptions outlined above.
Table 6 compares the worker dose estimates to the 2,4-D or picloram NOEL
derived from the most sensitive animal species tested with these herbicides.
Dose levels are not compared to the ADI values because all but one dose
estimate are above the ADI values.
Table 5. — Worker dose estimates for open-range application (Deer Creek
Project) .
Worst case dose
low
protection)
(mg/kg/day)
Worst case dose
( normal
protection)
Average dose Average dose
(low (normal
protection) protection)
iog^kg/day} (mg/kgyiJfly) —
2,4-D 0.21
0.07
0.09
0.03
ILii
0.05 iLJn 0^Q1_
Table 6. — NOEL/dose comparisons for worker doses.
Worst case dose
Worst case dose
Average dose
Average dose
low
( normal
( low
(normal
protection)
protection)
protection)
protection)
(mg /kg/ d ay}
(mg/kg/day)
Xofi/ks/dfly).
(mg /kg/dav)
2,4-D 4.8
14
11
33
Picloram 44
142
233*
700*
*Dose is below the ADI for picloram.
-10-
All picloram dose estimates indicate sufficient margins of safety to protect
worker health particularly if attention is paid to protective clothing and
careful application techniques. The potential worker doses from 2,4-D
applications have much lower margins of safety. Effects on kidney function are
possible! particularly if workers use sloppy application techniques and little
protective clothing.
Workers must be explicitly advised of the possible effects of 2j4-D application
and the necessity of careful techniques and protective clothing. The
relatively short period of application (3 weeks or less) and careful
application technique will minimize or eliminate health effects.
The worker cancer probabilities can be calculated for various dose estimates.
Assuming that a worker applies herbicide for 15 days a year for 5 years, the
worker cancer probability for 2,4-D would range from about four chances in 10
million to four chances in one million depending on dose estimates used.
Equivalent probabilities for picloram would range from three chances in 100
million to 1.5 chances in 10 million. As might be expected, these
probabilities are above those of the general public. However, they are still
within a range apparently accepted by society.
Worst-case Right-of-Way Project
Noxious weeds often spread initially along transportation corridors. As a
consequence, the Forest Service contemplates spraying along roads.
As indicated in Appendix 5 all ROW projects contemplated on the Gallatin NF
involve small amounts of herbicide (50 pounds or less) on scattered
infestations. The largest ROW project on the Gallatin National Forest is the
Smith Creek project on the Livingston Ranger District. This project involves
application of about 41 pounds (a.i.) of 2,4-D and 5 pounds of picloram on
scattered infestations along about 15 miles of road (30 miles of roadside).
The Background Document analyzes impacts of several different herbicides and
application amount on ROW projects. Exposure and dosage values for 2,4-P
application on the the Smith Creek project are based on a model ROW project
involving application of 48 pounds of 2,4-D. Picloram values are based on dose
estimates for a model project involving application of picloram (6 pounds a.i.)
in combination with 2,4-D.
Since the projects contemplated here would involve less pesticide which would
be applied over a larger area, the worst-case risk factors developed for the
generic projects will be used to estimate the actual risk levels.
The worst-case estimates of dose levels have been developed for residents
within 60 meters (200 feet) who are exposed directly to drift and who eat
garden vegetables contaminated with drift. The dose to an adolescent who might
walk within 1 yard of a spray rig during application and the dose to a person
who re-enters the spray area after spraying has occurred is also calculated.
-11-
Because many roads are located ir ’'alley bottoms, impacts on water sources are
possible. The Background Document assumes a stream flowing at 1 cubic foot of
water per second. This flow rate is similar to flow rates of smaller streams
in the vicinity of ROW projects on the Gallatin NF. For example. Smith Creek
has a flow rate of 12 cfs and Stag Creek, a tributary of Smith Creek near the
project, has a flow rate of 1 cfs.
Table 7 summarizes worst-case doses for right-of-way projects as derived from
Section 2.4.6 of the Background Document (Tables 2.32 and 2.33).
Table 7. — Worst-case daily dose to residents in the vicinity of right-of-way
projects sprayed with mixtures of 2 ,4-D/pic loram.
2,4-D
(mg/kg/dav)
Pic loram
(mg/kg/dav)
Adult dermal dose
0.00004
0.0000005
Adolescent dermal dose
0.038
0.0005
Infant dermal dose
0.000096
0.0000012
Adult/adolescent oral dose (beef)
0.0000071
0.0000071
Infant oral dose (beef)
0.0000083
0.0000083
Adult/adolescent oral dose (veg)
0.0010
0.00013
Infant oral dose (veg)
0.0013
0.00015
Visitor re-entry or walk along ROW
0.0018
0.00023
Adult oral dose (water)
0.0058
0.00072'
Adolescent oral dose (water)
0.0076
0.001
Infant oral dose (water)
0.0083
0.0011
Adult/adolescent oral dose (fish)
0.00010
0.000017
Infant oral dose (fish)
0.00011
0.000019
Table 8 provides ADI/dose comparisons for various maximum-exposed individuals
who are assumed to receive a combination of doses.
-12-
Table 8. — ADI/dose comparisons for maximum-exposed residents and visitors in
the vicinity of right-of-way projects sprayed with 2 ,4-D/picloram
mixtures .
2.4-D
Pic loram
Adult resident
1.4
29
Adolescent resident
(dermal and oral dose)
Above
15
Adolescent resident
(oral doses only)
1.1
22
Infant resident
1.0
21
Visitor rc-entrv __ .
^
liI2
The only dose that might exceed the ADI would occur if a person "tagged" along
with the spray crew applying 2,4-D. As discussed in Section 2. 4. 6. 2 of the
Background Document, the method of calculating this dose was extremely
conservative and this dose would likely never occur. If this dose did occur,
it would be less than the 2,4-D NOEL (based on long-term animal exposure tests)
by a factor of 21. Since this dose would occur only for a day, health would
not be affected.
Cancer probabilities for all potentially exposed individuals would be well
below those calculated for open-range projects (see Section 2.7.8 of the
Background Document) .
Right-of-way projects would involve herbicide application from a truck with
less potential exposure to workers. Thus, worker dose and risk would be less
than that calculated for open-range projects.
Potentially
s
Application of small quantities of 2,4-D or picloram is proposed in several
campgrounds and administrative sites. Two exposure pathways of concern are
dermal contact with sprayed vegetation and soil, and the consumption of sprayed
wild food.
All camp sites will be closed and posted during spraying and for 2 days after
spraying. In addition, at least half of he 2,4-D herbicide can be expected to
disappear from the campground in 2 weeks because of the herbicide s low
persistence in the environment. Thus, doses to persons re-entering the sites
will be lower than the visitor doses calculated for open-range projects. As
discussed in the Background Document (Section 2. 4. 3. 4), the removal of
herbicides from sprayed surfaces is very difficult within a short time after
spraying .
-13-
%
Any wild foods sources such as berry bushes would still be in blossom or in
early reproductive stages when spraying occurs. Thus, consumption of wild food
would not be possible. If bushes were accidentally sprayed the herbicidal
action on these bushes would prevent fruit development. Thus, doses to a
person consuming any wild foods would be less than that calculated for
open-range projects.
Dose to workers would also be less than open-range calculations because very
little herbicide is applied per day (less than 2 pounds of active ingredient).
Major Accidents
The effect of a major truck spill of 300 gallons of herbicide mix containing 22
pounds active ingredient of herbicide into various drinking water reservoirs is
discussed in Section 3 of the Background document. The spray programs in the
Gallatin NF will involve spraying near drinking water sources for the town of
Bozeman. The worst-case spill scenarios in the Background Document indicate
the effect of a major spills into streams feeding reservoirs typical of those
in the Gallatin National Forest area. Assuming only dilution, the highest
herbicide dose to an adult drinking 2 liters of this water would be 0.014
mg/kg. This dose slightly exceeds the ADI for 2,4-D and is less than the ADI
for picloram. Doses at this level would occur only for a day since
concentrations in water would be quickly diluted. Long-term health impacts are
not expected.
Section 3.2.1 of the Backgrbund Document discusses the probability of various
types of truck accidents. Based on these calculations and on assumption of
5,000 miles of pesticide truck travel per year, a truck accident resulting in
spill of pesticides would occur less than once every thousand years on the
Gallatin National Forest. Spills into water would occur less frequently.
REFERENCES
Davies, J. E. , V. H. Freed, H. F. Enos, R. C. Duncan, A. Barquet. 1982.
Reduction of pesticide exposure with protective clothing for applicators
and mixers. Jour, of Occupational Medicine 24: 464-468.
Libich, S., J. C. To, R. Frank, and G. J. Sirons. 1984. Occupational
exposure of herbicide applicators to herbicides used along electric power
transmission line right-of-way. Am. Ind. Hyg. Assoc. J. 45(1): 56-62.
Waldron, A. C. 1985. Minimizing pesticide exposure risk for
applicator, and field worker. In, Dermal exposure related
use. Honeycutt, R.C., G. Zweig, and N. N. Ragsdale, eds.
Series No. 273. American Chem. Soc .
the mixer loader,
to pesticide
ACS Symposium
-14-
APPENDIX 9 a
Specimen Label
RESTRICTED USE PESTICIDE
For retail sale to and use only by Certified Applicators or persons under their direct supervision and only for those uses
covered by the Certified Applicator's certification.
Totdon* 22K
Weed Killer
Active Ingredient(s):
Picloram (4-amino-3,5.6-trichloropicolinic acid), as the potassium salt
Inert Ingredients
Acid Equivalent;
Picloram (4-amino-3,5,6-trichloropicolinic acid) - 21.1% - 21b/gal
E.P.A. Registration No. 464-323
E.P.A. Est. 464-MI-1
KEEP OUT OF REACH OF CHILDREN
CAUTION
AVISO:
PRECAUCION AL USUARIO:
Si usted no lee ingids, no use este producto hasta que la
etiqueta le haya sido expllcada ampliamente.
PRECAUTIONARY STATEMENTS
Hazards to Humans and Domestic Animals
Physical or Chemical Hazards
Do Not Cut or Weld Container.
Environmental Hazards
Do not apply'directly to water. • Do not
apply where runoff is likely to occur. • Do
not contaminate water by cleaning of
equipment or disposal of wastes. • Do not
contaminate irrigation ditches or water used
for irrigation or domestic purposes.
MAY CAUSE IRRITATION
Avoid Contact With Skin And Eyes • Avoid
Breathing Spray Mist • Keep Container
Closed
STATEMENTS OF PRACTICAL TREATMENT In cate of
contact, immediately flush eyes or skin with plenty of
water. Get medical attention if irritation persists. It
twallowed, induce vomiting immediately by giving two
glasses of water and sticking finger down throat. Call a
physician. Do not induce vomiting or give anything by
mouth to an unconscious person.
NOTICE
FiBatl the entire label. Use only according to label
Before buying or using this product, read •'WARRAN-TY
LIMITATIONS AND DISCLAIMER' elsewhere on this label.
If terms are not acceptable, return unopened package at
once to seller for full refund of purchase price paid.
Otherwise, use by the buyer or any other user constitutes
acceptance of the terms under the Limit of Warranty and
Liability.
IN CASE OF AN EMERGENCY
endangering life or property Involving this
product, call collect 517-636-4400
AGRICULTURAL CHEMICAL
Do Not Ship or Store with Food, Feeds,
Drugs, or Clothing
READ THE FEDERAL LABEL AND
APPROPRIATE STATE LABELS
BEFORE USING THIS PRODUCT
Tordon* 22K
CONTENTS PAGE NO.
FEDERAL (E.P.A.) LABEL 2
SPECIAL LOCAL NEEDS
Arizona 3
Idaho 4
Idaho 5
Iowa 6
Kansas / 6
Kansas 7
Minnesota 8
Missouri 9
Montana 10
Montana 11
Nebraska 12
Nevada . . 4
North Dakota 13
Oklahoma 15
Oregon 4
Oregon 5
South Dakota 16
Texas 17
Utah 4
Utah 18
Washington 4
Washington 5
Wyoming 20
SUPPLEMENTAL USE LABELS,
California- 22
Colorado 24
Hawaii 25
Nebraska 25
FEDERAL (E.P.A.) LABEL
GENERAL INFORMATION
Use TORDON 22K Weed Killer on non-cropland areas such
as fence rows, around farm buildings, equipment path-
ways and roadsides, to control annual and deep rooted
perennial weeds such as Absynth wormwood • Bracken-
fern - Buffalo bur - Bur ragweed - Burroweed - Cactus
species - Camel thorn - Catclaw acacia • Chaparral species
Dock - Firebrush - Field bindweed (perennial morning-
glory) - Fringed sagebrush - Gambel oak - Goldenrod -
Gorse • Guava - Hau - Horsenettles, Carolina, white - Java
plum • Junipers • Knapweeds, diffuse, Russian, spotted
squarrose • Lantana - Larkspurs - Leafy spurge - Live oak -
Locoweeds - Lupines - Melastoma - Mesquite - Ox-eye
daisy - Milkweed - Pamakani - Poison Oak - Pinyon -
Pricklypear cactus - Flabbitbrush - Rush skeletonweed -
Scotch broom - Snakeweeds - Sowthistle - Starthistles,
Iberian, purpie, yellow - Tansy ragwort - Toadflaxes -
Thistles, artichoke. Beaumont. Canada, distaff, golden,
Italian, musk, scotch, wavy leaf.
Picloram is highly potent, persistent and water soluble.
Tiny amounts can kill or injure many broadleafed plants. To
prevent damage to desirable crops and plants follow all
diractlona and pracautlona.
DIRECTIONS FOR USE
Do not uaa for manufacturing or formulating.
It is a violation of Federal law to use this product in a
manner inconsistent with its labeling.
Mix the required amount of TORDON 22K Weed Killer in
water and apply as a coarse low pressure spray using
ground equipment or aircraft. For best results treat when
the weeds are growing actively in the spring before full
bloom or late summer Into fall. Treatments during full
bloom or seed stage of some weeds may not give good
control.
For General Use on Perennial Weeds on Non-Cropland,
use 1 to 1-1/2 gallons of TORDON 22K Weed Killer per acre
in 50 to 100 gallons of water and spray to wet weed foliage
and soil. NOTE: Local conditions may affect the use of
herbicides. State agricultural experiment stations or ex-
tension service weed specialists in many states issue
recommendations to fit local conditions. Be sure that use
of this product conforms to all applicable regulations.
For Use As A Spot Treatment on Perennial Weeds. Mix at
the rate of 1 gallon of TORDON 22K per 100 gallons of water.
Apply at the rale of 100 gallons of spray mixture per acre.
This will provide a rate of 2 pounds of picloram per acre.
For small amounts use 2-1/2 fluid ounces TORDON 22K per
2 gallons of water. For round patches apply as indicated in
the table.
Fast tcrou Roend Patch Galloni
to be Ircsiad (waad araa of tpray mixtvra
plas 10 foot botdar) to apply
25 1.0
50 4.5
75 10.0
100 180
235 or (I acre) 100 0
Tank Mixture for Spot or Broadcast Treatment of Suscep-
tible Annual and Perennial Broadleaf Weeds: TORDON
22K may also be tank mixed with 2,4-D products such as
ESTERON* 99* Concentrate. FORMULA 40*. DMA* 4, or
ESTERON 6E herbicides for use on areas having mixed
species including those which respond well to 2,4-D. Read
and follow all directions and use precautions on other
product labels.
Be Sure You Follow All Use
Precautions Given on This Label and
Remember These Key Points
1. Use only the recommended amounts.
2. Picloram is persistent. It will carry over in the soil.
3. TORDON 22K is water soluble. It can move with water in
irrigation or drainage ditches.
4. Spray drift can damage crops.
USE PRECAUTIONS
Use this product only as specified on this label Observe
any special use and application restrictions and limita-
tions, Including method of application and permisaable
areas of use as promulgated by state or local authorities.
Do Not .Apply or Otherwise Permit TORDON 22K or
Sprays Containing TORDON 22K to Contact Crops or
Other Desirable Broadleaf Plants including but not lim-
ited to alfalfa, beans, grapes, melons, peas, potatoes,
safflower, soybeans, sugarbeets, sunflower, tomatoes,
and other vegetable crops, flowers, fruit plants, ornamen-
tals, shade trees nor the soil containing roots of nearby
valuable plants.
Avoid Injurious Spray Drift: Applications should be made
only when thero is no hazard from spray drift since very
small quantities of the spray, which may not be visible, may
severely injure susceptible cropsduring both growing and
dormant periods. To minimize spray drift use low spray
pressure, under 30 psi; spray when wind velocity is less
than 10 mph; and apply as a coarse spray. To aid in further
reducing spray drift, a drift control and deposition aid such
as NALCO-TROL(I) may bo used with this product. If such
a drift control aid is us^, follow all use recommendations
and precautions on the product label.
(I)NALCO-TROL - Trademark of NALCO Chemical
Company
Ground Equipment: With ground equipment spray drift
can be lessened by keeping the spray boom as low as
possible: by applying 20 gallons or more of spray per acre;
by using no more than 30 pounds spraying pressure with
large droplet producing nozzle tips; by spraying when
wind velocity is low; and by stopping all spraying when
wind exceeds 10 miles per hour. Do not apply with hollow
cone-type insecticide or other nozzles that produce fine-
droplet spray.
Aerial Application: With aircraft, drift can be lessened by
using straight stream nozzles directed straight back, and
by using a spray boom no longer than 3/4 the wing span of
the aircraft.
Determine Air Movement and Direction Before Foliar
Application: Do not spray when wind is blowing toward
2
susceptible crops or ornamental plants near enough to be
in/ured It Is suggested that a continuous smoke column at
or near the spray site or a smoke generator on the spray
equipment be used to detect air movements, lapse condi-
tions. or temperature inversions (stable air). If the smoke
layers or Indicates a potential of hazardous spray drift, do
not spray.
Do Not Conlamlnala Water Intended for Irrigation or
Domestic Purposes. To avoid injury to crops or other
desirable plants do not treat or allow spray drift to fall onto
Innerbanks or bottom of irrigation ditches or other chan-
neis that carry water that may be used for irrigation
purposes.
Do Not Move Treated Soil To Other Areas. Do not use it to
grow plants, unless adequately sensitive bloassay or
chemical tests show that nodetectable picloram is present
in the soil.
Do Not Mix with Dry Fertilizer.
STORAGE AND DISPOSAL
Prohibitllons: Do not contaminate water, food, or feed by
storage or disposal. Open dumping is prohibited.
Pesticide Disposal: Pesticide, spray, mixture, or rinsate
that cannot be used or chemically reprocessed should be
disposed of In a landfill approved for pesticides or buried
in a safe place away from water supplies.
Container Disposal: Do not re-use containers (or
TORDON 22K herfokkie for any purpose. Dispose by
punching holes in them and burying with waste or by
taking to an approved landfill. Where indicated, follow
official local container disposal regulations. Plastic con-
tainers may also be disposed of by incineration or, if
allowed by state and local authorities, by burning. If
burned, stay out of smoke.
Rinse application equipmeot after use, at least three times
with water, and dispose of rinse water in a non-cropland
area away from water supplies.
General: Consult federal, state or local disposal au-
thorities for approved alternative procedures.
SPECIAL LOCAL NEEDS
I
3
MONTANA EPA SUN NO. MT-780003
For the Control of Broadleat Weeds In Rangelands, Perma- •
nent Grass Pastures, Spring Barley and Oats, and Spring
and Winter Wheat.
DIRECTtONS FOR USE
It is a violation of Federal law to use this product in a
manner inconsistent with Its labeling.
Read complete use directions and precauttons on this
label and container label before using.
Rangeland and Pasture
Use TORDON 22K Weed Killer to control broadleaf annual
and perennial weeds such as Canadian and other thistles,
field bindweed, leafy spurge, Russian knapweed, spotted
knapweed, tall larkspur, yellow toadflax, locoweed, snake-
weed and lupines on rangeland and permanent grass
pastures. Treat when weeds are growing well using low
pressure sprays. Retreatment at the same rate may be
necessary the following year.
Spot Treatment: (ground application only) Use TORDON
22K at rates of 2 to 4 quarts In 20 to 100 gallons of water per
acre and apply as a spray to the foliage. Use the higher
rates to control leafy spurge, larkspur, toadflax and knap-
weed. Use the lower rates for bindweed and thistles. For a
1,000 square foot Infestation, apply about 2-1/4 fluid
ounces of TORDON 22K in 1 gallon of water (equivalent to 3
quarts per acre of TORDON 22K),
NOTE; When spot treating, do not cut grass for feed within
2 weeks after treatment. Meat animals grazing for up to 2
weeks after treatment should be removed from treated
areas 3 days prior to slaughter. Do not graze dairy animals
on treated areas within 2 weeks after treatment.
Broadcast Treatment: (ground or aerial application) to
suppress the growth of many perennial hroadleaf weeds,
apply as a broadcast spray using 1 quart of TORDON 22K In
1 to 4 gallons of water per acre by air or In 20 to 100 gallons
of water per acre by ground equipment and apply as a
broadcast spray during the growing season when weeds
are growing well. (Many seedling annual weeds can be
controlled using 1 pint per acre.)
Tank Mixture for Spot or Broadcast Treatmente: TORDON
22K may also be tank mixed with 2.4-0 products such as
ESTERON* 99* Concentrate, FORMULA 40*, DMA* 4 or
ESTERON 6E herbicides lor use on areas having mixed
species including those which respond well to 2.4-D, such
as big sagebrush In tank mix combinations, use 1 pint to 1
quart of TORDON 22K with I to 2 quarts ESTERON 99
Concentrate. FO(?MULA 40 or DMA 4. or with 2/3 to 1-1/3
quarts of ESTERON 6E per acre, in spray volumes spec-
ified above. Read and follow all directions and usa pra-
cautlona on other product labels.
Spring Barley and Oats, Spring and
Winter Wheat not Underseeded with
a Legume
For the control of wild buckwheat and other annual broad-
leal weeds normally controlled with 2.4-0 or MCPA such as
wild mustard, Russian thistle, pennycress. lambsquarters
and pigweed, in spring wheat and barley and winter wheat,
use TORDON 22K as a tank mix with a 2.4-D or MCPA
formulation such as DMA 4, FORMULA 40. ESTERON 99
Concentrate, ESTERON 6E, or MCP Amine Herbicides. For
se on spring oats, tank mix only with MCP Amine Her-
icide. Read and follow all directions and usa precsu-
ttons on other product labels.
Spring Wheat, Barley and Oats: Apply during the 3
through 5 leal stage of growth. Application of TORDON
22K occasionally causes slight head malformations and
Straw shortening but normally this does not affect yield.
Durum Wheat: Do not treat durum since at least some
varieties appear to be more. sensitive than other wheat.
Winter Wheat: Apply after resumption of active growth in
the spring and before the early boot stage.
For aerial or ground treatment, usa enough total spray
volume to provide adequate spray coverage. Apply 1 to 4
gpa by air and 5 to 20 gpa by ground. Spray pressure
should not exceed 30 psi. Use a coarse spray to minimize
^pray drift.
To prepare the spray, mix only with water. Add about half
the desired amount of water in the spray tank. Then with
agitation, add the recommended amount of TORDON 22K
and 2.4-0 or MCPA as outlined in the table. Finally, with
continued agitation, add the rest of the water.
'The dosages recommended equate to 1/4 oz. picloram -f 4
oz. 2,4-D or MCPA aa/acre when weeds are small or 3/8 + 6
ozJacra when weeds^re more advanced or when dry soil
conditions exist.
Use Rates (or Barley. Oats, and Wheat
Amouats of Each Prsduet Par Acre t
Wssd
Grewlh
Sligs
DMA 4. FORMULA 40
ESTERON »
Concsntrsis or
TOROON 22K plat MCP Amies sr ESTERON SE
wssdi 1-3
IIKhSi till
1 II. 01.
Vi pt.
Vi pt
wisdt 3-6
inchss till
or under dry
1Vi II 01
Vi pt
Vi pt
conditions
kfWhsn measuring small amounts of TOROON 22K wstd killer,
speciel care should be taken not to eiceed suggested rates
NOTE: Uee only on land that will be planted the following
year to grass or grain crops such as small grains, com,
Mrghum, or flax. Do not apply mora than 3/1 ounce
^loram per acre during any 12-month period.
USE PRECAUTIONS
Usa this product only as specified on this label. Observe
any special use and application restrictions and limita-
tions, Including method of application and permissible
areas of use as promulgated by state or local authorities.
Do Not Contaminate Nontarget Land Areas, Cropland,
Water, or Irrigation ORches. Do not apply directly to
standing or running water. Do not apply where surface
water from treated areas can run off to adjacent cropland,
either planted or to be planted, or Into streams, irrigation
V
4
i
ditches, irrigation ponds, or wells Do not clean conlainers
nor application equipment on or near these areas. Do not
apply on inner banKs or bottom ot irrigation ditches
Do not apply on or In the vicinity ol auacapllbla crops or
datirablo plants Including allalla. beans, grapes, melons,
peas, potatoes, satllower. soybeans, sugar beets, sun-
flower. tomatoes and other vegetable crops, flowers, fruit
plants, ornamentals or shade trees.
Avoid Spray Drtft: Applications should be made only when
there Is no hazard from spray drift since very small quan-
tities of the spray, which may r>ot be visible, may severely
injure susceptible crops during both growing and dormant
periods. Use coarse sprays to minimize drift since, under
adverse weather conditions, fine spray droplets may drift a
mile or more. The spray thickening agent, NALCO-
TROLfl), may be used with this product to aid In reducing
spray drift. If used follow all use recommendaliona and
precautions on the product label.
(1) NALCO-TROL - Trademark ol NALCO Chemical.
Company
Ground Equipment: With ground equipment, spray drift
can be lessened by keeping the spray boom as low as
possible; by applying 20 gallons or more of spray per acre;
by using no more than 30 pounds spraying pressure with
large droplet producing nozzle tips; by spraying when ^
wind velocity Is low; and by stopping all spraying when
wind exceeds 10 miles per hour. Do not apply with hollow |
cone-type Insecticide or other nozzles that produce a fine- 1
droplet spray.
Aerial Application: With aircraft, drift can be lessened by
applying a coarse spray; by using no more than 30 pounds
spraypressure at nozzles; by using straight stream nozzles |
directed straight back, by using a spray boom no longer |
than 3/4 the wing span of the aircraftt and by spraying only
when wlnd’veloclty is less than 10 mph.
Do Not Apply By Aircraft When An Air Temperature •
Inversion Exists: Such a condition is characterized by
little or no wind and with air temperature lower near the
ground than at higher levels. The use of a continuous
smoke column at or near site of application or use of a
smoke generating device on the aircraft is suggested to
indicate direction and velocity of air movement, and to
IrKlicate a temperature inversion by layering of the' smoke.
Do not rotate treated rangeland or pasture to other crop
uses. i
Do not spray pastures or grain If the forage legume |
component Is desired. TORDON 22K Weed Killer may i
injure or kill legumes. Also new legume seedlings may not |
be successful if made within 2 years following application j
of this herbicide. ,
Do not move treated soil to other areas. Do not use it to
grow plants, unless adequate sensitive bioassay or chemi-
cal tests show that no delectable picloram is present in the
soil.
Do not transfer livestock Irom treated grass areas onto
broadleal crop areas without first allowing 7 days of
grazing on untreated grass pasture. Otherwise, urine may
contain enough picloram to cause injury to sensitive ,
broadleaf plants. '
Do not re-use containers lor TORDON 22K Weed Killer lor
any purpose. Dispose by punching holes in them and
burying with waste or by taking to an approved landfill.
Where Indicated, follow official local container disposal
regulations.
Rinse application equipment alter use, preferably at least
three times with water, and dispose of rinse water in a non-
cropland area away from water supplies.
Be sure that use of this product conforms to all applicable '
^ regulations.
Do not use where a sandy porous surface and substrata
overlie ground water 10 feet or lets bel^w the surface.
SPECIMEN LABEL 86-1754 DATE CODE
All 84
REPLACES 86-1754 DATE CODE 784
DISCARD PREVIOUS SPECIMEN LABELS
lEVISIONS INCLUDE;
1 revised FEDERAL EPA LABEL TO
2)
PRECAUTIONS.
ADDED APPROPRIATE PLASTIC
CONTAINER DISPOSAL PROCEDURE.
SL3080
5
APPENDIX 9b
Specimen Label
RESTRICTED USE PESTICIDE
For retail sale to and use only by Certified Applicators or persons under their direct supervision and only for those uses
covered by the Certified Applicator's certification.
TORDON
Pellets Herbicide
*
Active Ingredient(s):
Picloram (4-amino-3.5,6-trichloropicolinic actd), as the
Inert Ingredients
Picloram acid equivalent - 2.0%
E.P.A. Registration No. 464-333
E.P.A. Est. 464-MM
potassium salt
. 2.3%
97.7%
KEEP OUT OF REACH OF CHILDREN
CAUTION
AVISO:
PRECAUCION AL USUARIO:
Si usted no lee ingl6s, no use este producto hasta que la
etiqueta te haya sido explicada ampliamente.
PRECAUTIONARY STATEMENTS
DUST CAUSES IRRITATION • MAY BE
HARMFUL IF SWALLOWED
Avoid Skin and Eye Contact • Wash After
Handling
Environmental Hazards
Keep out of lakes, ponds, and streams. • Do
not contaminate water by cleaning of
equipment or disposal of wastes.
NOTICE
Read the entire label. Use only according to label
directions.
Before buying or using this product, read "WARRANTY
LIMITATIONS AND DISCLAIMER': on back panel. If terms
are not acceptable, return unopened package at once to
seller for full refund of purchase price paid. Otherwise, use
by the buyer or any other user constitutes acceptance of
the terms under the Limit of Warranty and Liability.
IN CASE OF AN EMERGENCY
endangering life or property involving this
product, call collect 517-636-4400
AGRICULTURAL CHEMICAL
Do Not Ship or Store with Food, Feeds,
Drugs, or Clothing
TORDON^ 2K
CONTENTS
FEDERAL (EPA) LABEL 2
SPECIAL LOCAL NEEDS 2
Idaho(A) 2
Idaho(B) 3
Minnesota
Montana 5
Nevada . / 2
North Dakota 2
Oregon(A) 2
Oregon(B) 3
South Dakota 2
Utah 2
Washington(A) 3
Washington(B) 6
Wyoming 2
FEDERAL (EPA) LABEL
TORDON 2K Pellets herbicide applied to the soil over plant
roots is highly effective for the control of broadleaved
perennial and annual weeds and undesirable woody plants
on utility, highway and other right-of-ways, fencerows.
headlands around farm and industrial buildings and stor-
age sites.
USE DIRECTIONS
Do not use for manufacturing or formulating.
It is a violation of Federal law to use this product in a
manner inconsistent with its labeling.
For Control of Broadleaved Perennial and Annual Weeds;
Apply TORDON 2K Pellets uniformly anytime during the
normal growing season where sufficient moisture is avail-
able to carry the herbicide into the soil. In areas where littje
or no summer rainfall occurs, application should be made
in late summer or early fall. Maximum effects of the
treatment do not become apparent until the chemical has
been carried by moisture into the soil.
TORDON 2K Pellets herbicide is effective against a wide
range of weeds. Local conditions may affect the use of
herbicides Consult your State Agricultural Experiment
Station or Extension Service weed specialists for local
recommendations. Be sure that the use of this product
conforms to all applicable regulations
ForControl of Woody Plantssuch asmaple. locust, aspen,
conifers, other woody trees, shrubs, wild rose, brambles,
wild grapes and other vines, apply TORDON 2K Pellets
uniformly to the soil over the root zone. Apply anytime
during the normal growing season where sufficient mois-
ture is available to carry the herbicide into the soil. In areas
where little or no summer rainfall occurs applications
should be made at "bud break" in late winter or early
spring Use at the rate of 300 to 400 pounds per acre
(equivalent to approximately 7 1/2 to 10 lb per -1000 square
leet. 2 to 2 1/2 lb per square rod, or 3/4 to 1 lb per 100 sq ft)
Maximum effects of the treatment do not become apparent
until the chemical has been carried by moisture into the
soil in the root zone ol the plants
APPLICATION RATES
Weeds
Controtledt
TORDON 2K
Peltets —
Amount
to apply
Remariis^
Docks
Larkspur
Pigweed
Povertyweed
Sowthistle
(perennial)
Sunflower
Tansy
Thistle
(plumeless)
Toadflax
(dalmation)
Bindweed
(field)
Bursage
(bur ragweed
woolyleaf
povertyweed)
Knapweed
(Russian)
Milkweed
Spurge
(leafy)
Thistle
(Canada)
50 to 100 lb.
per acre
19 to 37 oz
per 1000
sq. ft
5 to 10 oz.
per square rod
Too to 150 lb.
per acre
37 to 56 oz.
per 1000
sq. ft.
10 to 16 oz,
per square rod
Use lower rates in
low rainfall areas in
the northern states
such as Idaho.
Montana. North
Dakota. Oregon.
South Dakota, Wy-
oming. and Wash-
ington. Higher
rates should be
used where rainfall
is greater or in
southern states
such as Arizona,
Arkansas, Kansas.
Missouri, New
Mexico, Oklahoma
and Texas.
t These are typical examples of weeds controlled
USE PRECAUTIONS
Avoid Improper Application; This herbicide is highly ac-
tive against most broadleaved plants. Small quantities may
cause damage to plants whether applied during the grow-
ing or dormant season. Do not apply or otherwise permit
TORDON 2K Pellets to contact desirable plants such as
vegetables, flowers, grapes, fruit trees, ornamentals, cot-
ton. beans, soybeans and other valuable broadleaved
plants.'nor the soil containing roots of such plants growing
there on or nearby or where such plants are to be grown.
Avoid Water Contamination; To avoid crop or other plant
injury, do not treat inner banks or bottom ol irrigation and
drainage ditches Do not contaminate water to be used for
drinking or other domestic purposes.
Avoid Movement of Treated Soil: Avoid the movement of
treated soil into untreated areas.
Other Precautions: Do not store near food, feedstufis.
fertilizer, seeds, insecticides, fungicides or other
pesticides. To avoid injury to desirable plants, containers
and equipment used for TORDON 2K Pellets should not be
re-used to contain or apply other materials
Do Not Mix or Blend with Fertilizers.
STORAGE AND DISPOSAL
Do not contaminate water, food or feed by storage or
disposal
PESTICIDE DISPOSAL: Wastes resulting from the use of
this product may be disposed of on site or at an approved
waste disposal facility.
CONTAINER DISPOSAL; Refer to instructions on con-
tainer for proper disposal information.
2
£PA SLN No MT-^00011 ^
for the Control of Susceptible Broadleet Weeds end ^
■"<< Permerrent
DIRECTIONS FOR USE r
II IS a violation of Federal law lo use this product in a
manner inconsistent with its labeling
TORDON 2K Pellets Herbicide Is designed for application *
to soil for control of susceptible herbaceous and woody
plants by absorption through root pick-up.
Rainfall is needed after application to leach the picloram to
the roots Application can be made by hand or broadcast
equipment. Generally uniform distribution over the root-
zone of the plants in the intended site is desirable; how-
ever. certain species may be controlled by
the dose near the stem. Best results are usually obtained/
when rain follows shortly after application and shortly
before or during active growth Do not apply TORDON 2K
Pellets to frozen or saturated soil.
SUGGESTED USE RATES
oz/lOO
Ib/A
•q. ft.
Yellow starthistle, Scotch thistle,
musk thistle, spotted and diffuse
knaoweeds, lupines, locoweeds
25-50
1-2
Rush skeletonweed-Russian
kanpweed. Canada thistle. Tall
larkspurs, rabbitbrush,
burrowweed, snakeweed, fringed
sagebrush, common milkweed,
artichoke thistle, tansy ragwort,
common tansy, pricklypear and
cholla cacti.
50-100
2-4
Leafy spurge
100-150
4-6
TORDON 2K Pellets Herbicide at rates over about 75 lb per
acre may suppress certain grasses, such as wheatgrass,
bromegrass. buffalograss and bluegramma Usually, later
grass growwth will be improved by release from competi-
tion. Grass seedlings may be suppressed or killed up to 2 _
years after application at higher rates Broadleaf forage
plants, especially legumes, in treated areas may be injured
or killed and may not grow for 1 lo 2 years
RESTRICTIONS FOR PASTURE AND
RANGELAND USE
Limit coverage to no greater than 25% of an applicators
acreage found in any particular watershed
Do not use where a sandy porous surface and substrate
overlie ground water closer than 10 feet below the surface
Where watersheds have significant slope and where rapid
runoff can occur, use spot treatment only Do not apply
within 1/2 mile of where stream or pond water which drains
from the treated watershed may be drawn to irrigate
susceptible broadleaf crops, . especially beans and po-
tatoes Do not clean containers or application equipment,
on or near these areas.
Kill Of injury may occur to desirable forbs. trees or shrubs,
such as blackberry, cherry, locust, poplar, mountain ma*
>iqngany bitterbrush and sumac, from root uptake It such
efiects cannot be tolerated, do not apply on or near such,
desirable plants
Do not apply to cropland used lor production of desirable
crops other than forage species. Do not rotate treated
rangeland or pastures to other crops until residues of
picloram have reached a nonphytotoxic level Forage
legumes on the treated areas may be intured and may not
grow lor two years or more alter treatment
Head and follow all other use precautions on this label
USE PRECAUTIONS
A^ply this product only as specified on this label. The
active ingredient in TORDON 2K Pellets herbicide is water
soluble and should not be applied where surface water
from treated areas can run off to croplands either planted
or to be planted
Avoid use near desirable plants. This herbicide is water
soluble, highly active and can remain in the soil lor more
than one growing season. Very small amounts can injure
broadleaf plants such as potatoes, peas, beans, sugar-
beets or alfalfa; therefore, do not apply on or near these or
other susceptible plants, ornamentals, shade trees or
vegetable crops Do not plant these crops or plants in soil
that may have injurious amounts of this herbicide
Avoid movement of treated toil. Picloram may remain in
treated soil for an extended period Do not move treated
soil to other areas and do not use such soil lo grow plants
until residues have reached a non-phylotoxic level.
Avoid transfer of livestock from a treated area to a
broadleaf crop area without first allowing 7 days of grazing
on untreated pasture for the first 12 months after applica-
tion Otherwise, urine may contain enough picloram lo
cause injury to sensitive broadleaf plants Do not use
manure from animals grazing treated areas to fertilize soil
or fields used to grow susceptible broadleaf crops
Avoid water contamination. Do not allow TORDON 2K
Pellets herbicide to contaminate water used for drinking,
irrigation or other domestic purposes. Do not apply on
inner banks or bottoms of irrigation ditches. Do not clean
containers or application equipment on or near these
. areas
Avoid improper storage and equipment use. Do not store
near fertilizers, seeds, insecticides, fungicides or other
pesticides Containers and equipment used for TORDON
2K Pellets herbicide should not be used for other agri-
cultural chemicals since small residues of TORDON 2K
Pellets herbicide can damage desirable plants
Avoid improper disposal. Rinse equipment and dispose of
waste by burying in non-cropland away from water sup-
plies. Do not reuse containers Bury them with waste or
dispose in a sanitary landfill or follow official container
disposal regulations
Be sure that use of this product conforms to all applicable
state and federal regulations.
3
lute]
VoniVi", >
m
JW ?t4‘
4
t'r-'Vt
„ , ^^Hon'Diiciin'
(. ■«=? tf ■ . ..,, , , u
^T'V*4‘it» ■“■4*'«'-<!(t9>'v* tc iavl/.o;. H «Ig»,j;
_ U >''>‘t; .'.-,<I.V4, Ii' vr'-t
iyMir -avic-i^ „.,,, -.„.
m'-j.l- * .-liN,, j: ,J
■■' ifRW4 ijfil 1l -i_
v*.') trtlHI !>.'
1^.'^- .'ll- 'T)a.-. H/i* • . ill ^j;: u
,ivT- '.•'.r''-^/^s3)l
A riT=
r^^Ojfflr'i'C *»•' fl 'f'
(«> K- *?'!?t'Of (>J '.,1^7^.
'1 ’’ m
1*
Uni •^» ►i' .,’ >^'*
iil/ti »■? r/-.-. .,<; -I n
IMiti' ' #1(1 1 'TT‘ ~
P(ip4 ^/.'^.v ■ ',i
■rr*}-.*'.! !
fsv; I- «(v-? .<i.i,v' i3
it
•»orT’ 3*»i'w. w7t:
'H*
_ I -•>//, try
ft is-i .. .,• ^
C> ■' '■•.'• ' IV '
** ‘‘ ' •' .'a* IRISH' I." i(^. ')'
•ftt t. I'f. ’■-''
["^i:U Uk’AJ::..7v^A,p
I *ft 7f<ff , V»
!.V'"--'3t • 5. •.*. '/ -V.
!>*•- ^«ff*...|pr,.i: j,.„t ...
•"'> S 'J. [IK -!i ,
-■%<n» ^Jc^ Id 'tri3Mc3j»i'‘.-,i? fr .’ V,; , (1^ •». •
3 ,v !|w .?Sif. t, •pi(}'a<Twi*<;!in»'V.. j , i,. ^
' •l•S^I•■■'Pl■ ,-.„t
... ’'V • '
■'**** • .’ ■*. iim.fl'r .y‘‘
H I/- !V4.r
-.'r, 7 .,
Jnci^T. t..„. > \ li" 3„v. '- .,
» ■' ■’ .^|n.,in,.£/ .j
■ .!. 7*S T ^ ■
' **•«.,( '/|U< It/- '.l^
y-i C ftooDijaui !^^c- .ar*7c».
»'i.; 9:a;.-3i J.>ityn • •# ‘
*■' j-ji.hti-71 i.irt-^ n. - .•) .
■»■ 'j;(i >*.-n *. .,. njj
Jl,‘i1MQM. .'Wi.,.. ,rtJ|
t-‘‘»-’'' ■»»- 5-. -
K<_ i>ii?r'‘L' ';i . ;ii’il''
t'.i- ifC'p r, *i o>»*i!i/»i "Dj
s
» -'S- ? ’
APPtNUlX yc
WILBURN LUS
AMINE 4
2,4-D AMINE HERBICIDE
ACTIVE INGREDIENT Dimethylamine Salt ol
2 4 Oichlotophenojyacelic Acid
INERT INGREDIENTS
TOTAl
( quivaleni to 38 8% ol 2,4 Oichloiophenojyacelic acid oi 3 8 lb/ gal
Isomei speolic by AOAC Method 6 275. 13th Ed. 1980
EPA REGISTRATION NO 39511-84 2935
[PA ESTABLISHMENT NO {SEE CONTAINER)
46 7%
53 3%
100 0%
OIRtCTIOI^EO^lnt
It li a vioiaVnn oU edeul t a« m Ihii pioduct ir a mamin m. on
sjslenl with this labi'lmg
REENTRY STATEMENT. Do not enlei treali’d aieas without pfolectivc
clothing until sprays have di«) Piotectivc clothing should include hal
or othei suitable head covenng. long sleeved shirt and long legged
trousers, or • coverall type garment, shoes, and socks
Because certain slates may require more restrictive reentry intervals
lor various crops treated with this product, consult your State Depart
meni ol Agriculture lor lurther inlormalion
Wiitlen or oral warnings must be given to workers who are expected
to be in a treated aiea or m an a’ea about to be treated with this prod
ucl The tronl panel PRECAUTIONARY STATEMENTS should be read
to workers as well as the instruction not to enter until sprays have
dr«d When oral warnings are given, warnings shall be given in tan
guage customarily understood by workers Oral warnings must be gi«n
it there IS reason to believe lhat written warnings cannot be under
stood by workers Written warnings must include the following
inlormalion
OUTION Area treated with 2.4 0 on (date ol application) Do
not enter without appropriate protective clothing until sprays
have dried (inserl here Statements ol Piacbcjl TrealmenI as
on IronI panel )
R£AD ENTIRE BOORLFT BEFORE US»C TMtS
SEE CONTMNFR FOR ADOmONAL PRECAUDONART SIATWENTS,
STORTUiE AND D4SPOSAE AND FIRST AID INFORMATION.
Page 1
STORAGE AND DISPOSAL
STORAGE: Do nol contaminate water, lood, or leed Iw
or disposal Open dumping is prohibiled Do not slore
uct near lerblizeis. seeds, insecticides, or lungodK tontain
ers should not be stacked more than six (6) high Reewse aii
parhalty used containers by thoroughly tightening screw cap
Damaged or leaking conUiners which cannot be used immedi
ately should be Iranslerred to suitable sound containers and
property marked Absorb any spRI with a suitable clay at^rbanl
and dispose ol as indicated under "Pesticide Disposal
Tor salety and prevenhon ol unauthorued use. all pesticides
should be stored in locked tacikties
To prevent accidental misuse, ditlerent peshcides should be
stored in separate areas with enough distance between to pro
vide clear idenWicabon
Opened, partially used pesticides should be stored in original
iaPeiW containers when possible When transfer to another
container is necessary because ol leakage or damage, care
luRy mark, and rienWy contents ol the new container
PtSTKtDE DISPOSAL Pesticide wastes art toxic Improper
doposal ol excess pesbade. spray mixture, or rmsite o i i^
hbon ol federal taw tl these wastes cannot be disposed ol^
use according to label instructions, contact your State Pe^
ode or Environmental Control Agency or the HararrtousW^
tepresentabve at the nearest EPA Ragiooal Office kx guidance.
CONTAINER DISPOSAL Container disposal Instnidli^^
with type ol contiinef used ter packaginc produrt See actual
container label lor complete contarner dtsposal aistructons
CfNERAl INFORMATION
Perlormance ol thrs produd may be affected by local condibons, OTP
^rappfeC niethod User
swn service agricultural expenmenl, or unrversity weed speoaksts.
and state legutalory agenoes lor recommendations in your area
Best results are obtained when produd « ‘P**^*®
Meds that are acbvety growing Appkeabon rates
mended wiR be sabstadory on susaptbfe annual
nial weeds and conditions such as
strtes, where conbol ts drtficult. the htgher recommended rates should
be used
VYhen produd is used lor weed conbol in crops, the growth stage ol
the crop must be considered
Some otants and weeds, especially woody variebes, are ditheutt to
S^li^^^bRuire repeal, ^tKxis./^^^
be 1 to 5 galons ol total spray by air or 5 to 25 galons b^ouM
0‘herwise dir«:ted In
amXl ol 2,4-0 recommended pet acre. "°P
with oil surfactants, or other adjuvants unless spedficalty recom
:;^'wSdTo<iosomayr«luceher^
result in crop damage
Aerial appfcition should be used only when there is no danger of d^
to suscepbSe crops. Many states have re^^s
ap5i^ of 2.4-D formulations.
b^mihingappications. This produd dintiins^ Orniethyb^
votabfe forms ol 2, 4^). Vapors rel^
bTtte produd are insafficteth to cause
bfe crops
Because coarse sprays are less Ikely to drift than fine, i>ono^«
aounneiit (such as holow cone smaB orifice nozzles) or condibons
(such as higfi pressure) that produce such sprays
Produd Miould not be alowed to ^
phnts such as beans, cotton. Itud bees, g^. BSume,
^^S^ts^peas, tomatoes and other
not be used in gteenhouses Excessive amounts o( Ito^uctlnltie
^ may temporal mhibd seed germination and all plant growth
Page 2
P^
4
Uscis should Hole Ih.d hetbiode InMliTU'nl of public «dtet renuires J
peimil born jppiopiiale sl.ileiscncies in most stiles Youi stale Con
seivalinn Depaitmenl. o( Cjme and I ish Commission mil aid you m
secuiing a permit in your state
II stored below Irce/ing. il may be necessary to warm product lo /U°l
and agitate belore using This does not alleci the cflioency ol the
product
Spray equipment used to apply ?,4 D should not be used lor any other
purpose until thoroughly cleaned with a suitable chemKal cleaner
Spray Prepatilion; Add the recommended amount ol product to ap
prourmalely one-hatl the volume ol water lo be used lor spraying Agi-
tate well, then add Ihe remainder ol Ihe water Continue agitation dur
mg application until spray tank is empty
Use in Liquid Nitrogen Fertiliaer: Product may be combined with liq
uid ndrogen lerliliaec suitable lor loliar application ol corn, grass, pas
lures, or small grains in one operation Use product according to di
rections on this label lor those crops Use liquid nitrogen lertilizer at
rales recommended by supplier or extension service specialist Mu
the product and lertilizer according to Ihe lollowing instructions
fill Ihe spray lank approximately Id lull with Ihe liquid nitro
gen lertilizer
In a separate clean container, mu Ihe amount ol product
lo be used with an equal amount ol water Add the product
mixture lo the spray tank while agitating Add Ihe remainder
ol Ihe lertilizer while continuing to agitate Apply immediately
maintaining agitation during application until tank is empty
DO NOT APPLY DURING COLD (NEAR FREEiING) WEATHER
Spray mixture must be used immediately and may not be
stored"
NOTE Pre-mixing Ihe product with an equal amount ol water is im-
portant
WHERE TO USE ■
This product IS used lo control broadleaved weeds in cereal crops,
corn, sorghum, weeds and brush in rangeland, pastures, rights-ol-
way. and similar noncrop uses, tree injecbon. and lor aquabc weed
control
Page 4
PLANTS CONTROLLED
Product will kill or control Ihe lollowing in addition lo many other nox
lous plants susceptible lo ?,4 D arrowhead, arbchoke, bindweed
(hedge. Iield, and Euroix’an), biller winlercress, box elder, buckhorn,
bull Ihistle, bulrush, burdock, bur ragweed, ground ivy. hemp, hoary
cress, honeysuckle, indigo, ironweed, iimsonweed, lambsquarters, lo 5
coweed, Mexican weed, morningglory, mustard, parrot leather, pen
nywort. pigweed, planlain, poison ivy. pokeweed, povertyweed, but
lercup. Canada thistle, calmp. chekweed. chickoiy. cocklebur, coHee
bean, creeping jenny, cuiley indigo, duckweed. ekJerbeiry, golden
rod. puncture vine, purslane, rush. Russian thistle, sagebrush,
shepherdspurse, smartweed, sow thistle, slinkweed, sumac, sunflower.
Virginia creeper, water hyacinth, water lily, water primrose, wild gar
lie. wild lettuce, wild onion, wild radish, willow, wilchweed
CROPS:
SMALL GRAINS NOT UNDERSEEDED WITH A LEGUME (BARLEY.
OATS, WHEAT, RYE): See table lor recommended use rates
Spray when weeds are small alter gram begins hllering but belore bool
stage (usually 4 to 8 inches tall) Do not apply belore Ihe tiller stage
nor Irom early bool through milk stage To control large weeds that
will interlere with harvest or lo suppress perennial weeds, preharvesi
trealmeni can be applied when the gram is in the dough stage Best
results wilt be obtained when soil moisture is adequate lor plant growth
and weeds are growing well
Spring Planted Oats: Apply m sutficrent water lo give good coverage
Apply alter the lully tillered stage, except during the boot lo dough
stage
Fad Planted Oah: Apply alter lull bllering but belore early bool stage
Some dilficull weeds may require higher rates ol 1 lo IVi pints per
acre lor maximum control, but injury may result. Do not spray during
or immediately lollowing cold weather
Note: Oats are less tolerant lo 2.4 D than wheat or barley and more
kkely to be injured Do not lorage or graze treated gram iields within 2
weeks alter treatment with 2,4 0 Do not teed treated straw to kvestock
Page 5
CORN: See table lot recommended use rales
Free mergence: Apply product Irom 3 lo 5 days after planting but be-
fore corn emerges. Do not use on very light, sandy soils. Use the
higher rates on heavy soils Plant corn as deep as practical
Post Emergence: Best results are usually obtained when weeds are
small and corn is 5 lo 18 inches tall When corn is over 8 inches tall,
use drop nozzles Do not apply Irom lasseling lo dough stage II corn
IS growing rapidly and temperature and soil moisture content is high,
use H pint per acre rale lo reduce possibility of crop damage Delay
cultivation for 8 to 10 days lo prevent stalk breakage due lo tempo-
rary brittleness caused by 2.4 D Appkabon rales of up lo 1 pintiacre
may be used to control some hard lo control weeds However, the
possibility ol injury lo the corn is increased
If corn is over 8 inches tall, use drop nozzles lo keep spray oft corn
foliage as much as possible. Do not use with oil. atrazine. or other
adjuvants Since the tolerance to 2,4 0 ol individual hybrids vanes,
consult your local Ezdension Service, Agricultural Experiment Station,
or University Weed Specialist lor informahon
Pre-Harvest; After Ihe hard dough or denhng stage, apply 1 lo 2 pints
of product per acre by air or ground equipment to suppress perennial
weeds, decrease weed seed produchon, and control tall weeds such
as bindweed, cocklebur, dogbane, jimsonweed. ragweed, sunflower,
velvetleaf. and vines that interTere with harvesting Do not forage or
feed corn fodder to livestock for 7 days following appAcabon
SORCHUH (Mlo): See table lor recommended rate. Apply to sorg-
hum when crop is 4 to 12 inches high with secondary roots well estab-
lished. Use drop nozzles when crop is over 10 inches high Do not
apply Irom flowenng lo dough stage Rates ol up to 1 pint per acre
may be used lo control some hard to control weeds However, the
chance of crop injury is increased with the higher rales. Do not use
with oil Use lower rate if condrhons ol high temperature and high soil
moisture exist
RICE: See table lor recommended rale Apply the product in sufficient
water to cover one acre when weeds are in acOve growth stage Rice
plants are sensitive to 2.4-D in early stages ol growth; therefore, rt is
advisabte to delay spraying unbi the second or third week after flooding
Water in the field should be shallow enough to permit direct applica-
tion ol the spray material to the weeds. Make all treatments well in
advance of treading
SUGARCANE: See table lor recommended rate. Apply as a pr^ or post-
emergent spray in the spring after canes emerge and through lay-by
Consult local Agricultural Experiment or Extension Service Weed Spe-
cialists on specific use ol this product, or in combinabon with Oowpon
M, to control broadleaved and grass weeds
RECOMMENDED RATE OF
AMINE 4 PER ACRE
Dvuft Pm
tociap)
i^ncrav)
;;pnfi| PuUi— ninrr
3itl
2/3tol 1/3 pam
Htolprt
2to 3
lHto2ianb
FVvtuncsKdoi^
1 to 2 pMtt
2to3Mnts
Con
Pmtiya
Frar^acs
PuifciHf
uplolacfetsM
8 netKS to ttsiMnc
(UU 04T^
Pri<ur«sl
2to4(Hti
Itmt
Htol pnl
1 to 2 pMts
lHto2Hc»«i
ScrjfUMO
8lo
(HMo«i»r<^tod lortr)
2/3tol(M<
1 prt
lHto?[w»ti
Rkx
1 to2Hpnts
2 to 3 pikA
2 to 4 patto
-Page /
4'agefi
2
not! Ihr It (ftomnwtyV-'l mij hr nwfVWi'i *<> • i*"!"*' *»■
►ws h rt'j tW'Oit'ii''*. •f>r '*rilrm ^^J1r^ I hr* \h«*oll «0l hr «V< h«*rvrt
wntr\i pu\gbtr r»op i w ri«Of* lltrt k* J> I ilrfljM" r 0'
Ar« I SUlion **W(J Sor »W liH on W«‘*' tond^iooi
*Aii/ofU W**«o Wofttom Onfon IJU'» Wlih-ofton Wyi»m»nt
*• H h»<«] hethwrt ri w»«d W'e floMff n«e on fhr « lu»l rtt tpuyed
ORNAMEIflAL TURF: Use 1 lo 3 pints ol product in enough water to
give good coverage to one acre on estabtished stands of perennial
grasses, depending on type ol weeds and stage of growth Do not use
on creeping grasses such as Bent except for spot spraying Newly
seeded lurl should not be treated until after the second mowing and
the lower dosage rale should be used
GRASS SEED CROPS; Apply 1 lo 4 pints ol ptoduci per acre in the
Spring or fall to control broadleal weeds in grass being grown lor
seed Do not apply from early bool lo milk stage Spray seedling grass
only after the five leal slage, using lo 1 pint per acre to control
small seedling weeds After the grass is well established, higher rales
ol up lo 4 pints per acre can be usedio control hard lo kill annual or
perennial weeds. For best results, apply when soil moisture is ade-
quate for good growth Do not use on Bent unless injury can be toler-
ated Do not grare dairy animals nor cut forage lor hay within 7 days
of application
FALLOM LAND; On established perennial species such as Canada this
lie and Field bindweed, apply up to 3 quarts ol product pei acre For
annuat broadleal weeds, apply 1 lo 2 quarts per acre Do not plant
any crop lor 3 months after treatment or unbi 2.4 D has drsappeared
from soil
ESTABLISHED PASTURES AND RAHGELAHDS. Use 1 to 4 pints ol
product in sufficient water lo give good coverage lo one acre depend
ing on type of weeds and stage ol growth Use only on established
stands of perennial grasses DO NOT graze dairy animals nor cut lor
age lor hay within 7 days of appheabon
Pages
For control of annual and perennial broadleal weeds, apply I to 2
quarts of product per acre in approximately 20 to 100 gallons ol total
spray Treat when weeds are young and acbvely growing belort the
bud or early Noom stage For harder lo control weeds, a repeat spray
may be needed after 3 lo 4 weeks for maximum results, using the
same rales
Apply no more than 2 treatments per season for woody brush and
patches ol perennial broadleal w^s. mix one gallon ol product in
IbO gallons ol water Wet foliage thoroughly, using approximately 1
gallon ol spray solution per square rod
Spraying insiruebons; low pressure (10 lo 40 psi) power spray
equipment should be used and mounted on a truck, tractor, or boat
Apply while traveling upstream lo avoid Kcidental concentrabon of
chemical into water Spray when the an is calm, 5 mph or less Do not
use on small canab (less than 10 C^S) where water will be used lor
drinking purposes.
Boom spraying onto water surface must be held to a minimum and no
cross stream spraying to opposite banks should be permitted When
spraying shoreline ameds, allow no more than 2-foot overspray onto
water with an average ol less than one-foot overspray to prevent in-
troduebon of greater than negigible amounb of chemical into the water.
Do not allow dairy animab to graze on treated areas for at least 7 days
after spraying. Water within treated banks should not be fished.
F()R A()UATK WEBB M LAKES, KWOS, DRAMAGE DFrCtlES, AHD
HAKSHES: Use 2K to 414 pmb of product in SO to 100 galons of
mter per Kie. Spray to wd lokage thoroughly Appheabon should be
made wrhen teaves are fuly developed above water ine and plants are
acbvely growing Your SM Consimrabon Department or Game and
Fish Commission wd assbt you in determineng the best bme and rate
for appiKjbon under local condibons.
DO HOT APflT lo more than 1/3 to 1/2 ol a like or pond in any one
month because excessive decaying vegetation may deplete oxygen
content of water, and kil hsh
Do not contaminate water used lor angabon or doiFiestic purposes
Perennial and other hard lo control weeds auy require a repeal appk
cation lo give adequate conbol
GENfRAl WIED CONIROI (Aulirkls. Koadsirtes V,n ,inl l of. liMin
age Ditch Banks. I rm e Hows. Industrial Sites and similar areas) Use
I lo 3 quarts nl (iro.lui I jifi acre tlsually 2 quarts jarr acre will give
adequate control Do not use on heibaccous ground covers or creep
ing grass such as Bent legumes will usually be damaged or killed
Deep-rooled perennials may require repeal applications Do not use
on freshly seeded lurl until grass is well established Delay reseeding
lor 3 months or until 2.4 D has disappeared from soil
WOODY PLANT CONTROL; To control woody plants susceptible lo
2.4 D. such as alder, buckbiush. ekfetberry. sumac, and willow on
non-crop areas, use 2 lo 3 quarts of product per acre in 1(X) gallons
ol water Wet all parts ol the plants thoroughly, including stem and
(oliage. lo the point ot run oft Higher volumes ol up to 400 gallons
per acre are necessary where the brush is very dense and over 6 lo 8
leet high Applications are more eflechve when made on actively grow
ing planb TrealmenI should nol be made during bme of severe drought
or in early Fall when leaves lose their green color Hard lo control
species may require re treatment next season
TREE INJECTION: For the control ol unwanted hardwoods such as
elm, oak, hickory, and sweetgum in forest and other non<rop areas,
apply undiluted product by injecting 1 ml through the bark, using one
injection per inch ol trunk diameter measured at breast height (4H
leet) For harder lo control species (ash, maple, dogwood), use 2 ml
ot undiluted product pet injection All injections should be as near the
root collar as possible and should be evenly spaced around the trunk
Injections may be made at any bme ot the year but are most ettechve
dunng the growing season Maples should nol be treated during the
spring sap rise
AQUATIC APPLICATIONS
WEEDS AND BRUSH OH IRRIGATION CANAL DITCHBAHAS - Seren
teen Western Stales Arizona, California, Cotorado, Idaho, Kansas,
Montana, Nebraska, New Mexico, Nevada, North Dakota, Oklahoma,
Oregon, South Dakota, Texas, UUh, Washington, Wyoming
Page 9
CONDITIONS OF
SALE AND WARRANH
WILBUR-ELLIS AND SELLER OFFER THIS PRODUa AND THE BUYER
AND USER ACCEPT THIS PRODUCT UNDER THE FOLLOWING AGREED
CONDITIONS OF SALE AND WARRANTY
The direchons lor use ol this product are believed to be reliable and
should be followed carefully However, it is impossible to take into
account all variables and to eliminate all risks associated with its use
Injury or damage may result because ol condibons which are beyond
the control ol Wilbur-Ellis or the Seller Wilbur-Elks warrants only that
this product conforms to the chemical description on the label and is
believed to be reasonably til lor the purposes referred lo in the Direc-
tions for Use when used as directed under normal condibons WILBUR
ELLIS MAKES NO OTHER EXPRESS OR IMPLIED WARRANTY OF FIT
NESS OR MERCHANTABILITY OR ANY OTHER EXPRESS OR IMPLIED
WARRANTY. In no case shall Wilbur-Eks or the Seller be kabte tor
consequential, special or indirect damages resulhng from the use or
handkng ol this product. Any variahon or excephon from this war-
ranty must be in wrihng and signed by an authorized Wilbur-Elks rep-
resentative.
Wilbur-EHs Company
PO Box 164S8
Fresno, Cakfornia 9375S
EPA EstaNishmenl No indcaled by tetter In Lot No: (A) 39511-AR 1
(B) 464-MI 1
(C) 39511 MTl
(0)40831 Ml 1
-Page 10
Page 11
Appendix 10
MONTANA NATURAL HERITAGE PROGRAM
< v>
TED SCHWINDEN. GOVERNOR MONTANA STATE LIBRARY BUILDING
STATE OF MONTANA—
1 H 1 S EAST BTH AVK.NU K HELENA , MONTANA 59620
(406) 444-3009
June 3, 1986
Chuck Sundt
Gallatin National Forest
Bozeman Ranger District
601 Nickles - Box C
Bozeman> MT 59715
Dear Chuck:
Please find enclosed information on sensitive» threatened,
and endangered plant species on the Gallatin National Forest.
Eight species are currently known to occur on N.F. land, and
information about seven of these is summarized in a copy of the
rare plant information taken from The Nature Conservancy Field
Office’s comments on the Forest Plan. Additionally, S4 species
are listed which have been reported from Gallatin, Madison,
Park, and Sweet Grass counties. Additional field surveys would
be needed to reveal the presence of these, or other , sensitive
plants on the Gallatin N.F.
The eight species listed first occur at higher elevations,
and thus may not be quite so subject to actions proposed in the
draft noxious weed EI5. However , the most efficient way to
assess possible impacts is to review the draft list of locations
(legals) to be treated. I would appreciate a copy of the EIS
for our office when it becomes available.
Also enclosed is a computer print-out of a special plant
location on the Gallatin from our data base, to illustrate the
information we store; and a copy of the special plant list I
have drawn up for the program. As our inventory is so new, and
our data base is hence still small, this information is subject
to change. You will note that some ranks (defined in the plant
list) have been changed from those given in the TNC information.
Please be sure to call if you have questions or need
further information.
Sincerely ,
iLi<
J. Stephen Shelly
Botanist
I
AN lOUAL OPPORJUNIJy EMPLOYER
NC comments Gallatin Plan
page three
RARE PLANTS ON THE GALLATIN NATIONAL FOREST
1. Erigeron f labellifolius (Fan-leaved daisy) G3/S1
Status ; Listed by The Nature Conservancy as threatened globally and
critically endangered in Montana. Listed as "rare" by the Montana Rare
Plant Project. Regional endemic, known from eight locations in Montana.
Habitat ; Talus slopes and gravelly soil above timberline, 9,000-11,000'
in the Beartooth and Crazy Mountains.
Location: a) Crazy Mountains, north of Sunlight Lake (NW 1/4 Sec. 8,
T4N, RllE). Common in open gravelly soil or exposed sites, especially
east facing slopes, b) Absaroka Range, West Boulder Plateau (NE 1/4 Sec.
12, T5S, RllE). A few plants located between coarse talus and the summit.
Management Recommendations : Sunlight Lake site needs to be assessed for
present and future threats from recreationists. Protection measures may
be necessary to protect the populations from motorized vehicle abuse or
trampling. The West Boulder Plateau site is probably adequately
protected by wilderness designation.
2. Townsendia condensata (Cushion townsendia) G3/S1
Status : Listed by The Nature Conservancy as threatened globally and
critically endangered in Montana. Listed as "rare" by Montana Rare Plant
Project. Small populations, known from only two mountain ranges in the
state .
Habitat: Rocky soil or talus above timberline, lower on limestone.
Location: Reported on the Montana-Wyoming border, south of Cooke Guard
Station, nw slope of "Ram Pasture"(?) above timberline.
Management Recommendations : This herbarium report has not been field
checked by TNC staff, and we are unable to determine the exact location
from this description. The site needs to be verified and assessed for
present and future threats.
f
3. Draba apiculata -var-r-ftpirgulata (Pointed draba) G3/S2
Status ; Listed by The Nature Conservancy as globally threatened and
'endangered in Montana. Listed as "rare" by the Montana Rare Plant
Project. Peripheral, known only from Madison County.
Habitat: Open ground above timberline, often on limestone in the Madison
Mountains . .
Location; Madison Range, east end of Taylor Basin '{Sec. 23, T9S, R2E).
Open frost-churned ground at the edge of a snowbank, limestone parent,
10,000' .
Management Recommendations : Protected by wilderness designation and
inaccessibility. Notify staff to be on watch for more occurrences.
TNC comments Gallatin Plan
page four
4. Draba ventosa (Wind River draba)
Status: Listed as "rare" by Montana Rare Plant Project. Two known
occurrences in state. Little information available.
Habitat t Rock ledges and talus slopes above timberline, often on
limestone .
Location: Madison Range, 1/2 mi, north of Koch Peak, on a talus slope of
a mountain on the east side of Koch Basin.
Management Recommendations : Protected by wilderness designation and
inaccessibility. Notify staff to watch for more occurrences.
5. Physaria saximontana var. dentata (Mountain twinpod) G3/S3T3
Status: This subspecies is listed by The Nature Conservancy as
threatened globally and in Montana. Recently split from Physaria
didymocarpa . Apparently a state endemic, but rare plant experts believe
it may be more widespread than current information indicates.
Habitat: Open soil, often rocky and often calcareous on slopes and
ridgetops at lower to high elevations.
Location: Crazy Mountains, near Sunlight Lake Mountain. Not visited by
TNC staff.
Management Recommendations: Site needs to be verified, and current and
future threats assessed. Presence of two rare plants in the Sunlight
Lake area warrants considering designation as an RNA or special botanical
area .
6. Erigeron gracilis (Slender fleabane) G4/S1
Status: Listed by The Nature Conservancy as apparently secure globally
but critically endangered in Montana. Listed as "rare" by The Montana
Rare Plant Project. Regional endemic. Four known occurrences in Montana.
Habitat: Meadows and open slopes at mid-to high elevations in the
Absaroka Mtns.
Location: West Boulder Plateau a) NE 1/4 Sec. 12, T5S, RllE; small, dry
meadow on north slope at 9,900'. b) Sec. 1, T5S, RllE; upper east slope
of the plateau at 9,900'.
Management Recommendations: Wilderness designation probably is adequate
protection. Presence of two rare plant species in the West Boulder
Plateau area suggests consideration of special designation as a botanical
area or RNA.
5.
T
TNC comments Gallatin Plan
page five
7. Potentilla brevifolia (Short-leaved cinquefoil) G4/S1
Status : Listed by The Nature Conservancy as apparently secure globally
but critically endangered in Montana. Listed as "rare" by The Montana
Rare Plant Project. Peripheral, common in NEV, ID. Only one known
occurrence in Montana.
.Habitat: Open, rocky slopes above timberline.
. Location; Madison Range (Sec. 15, TIOS, R2E). Ridge running south from
Expedition Pass ca. 20 mi. nw of West Yellowstone, east facing slope at
10,000' .
Management Recommendations : Protected by wilderness designation. Notify
staff to watch for more occurrences.
4
Live Music
Archive
Librivox
Free Audio
Metropolitan Museum
Cleveland
Museum of Art
Internet
Arcade
Console Living Room
Open Library
American
Libraries
TV News
Understanding
9/11